CAMPUS SECURITY AND
FIRE SAFETY REPORT
2021
For information or security services, call 781-891-2201 1
Hello and welcome to the Bentley University Annual Campus Security
and Fire Safety Report. Within, you will nd important information
regarding campus safety, crime prevention and reporting, the RAVE
emergency notication system, and various programs offered by our
police department. Additionally, in compliance with the Jean Clery Act,
you will nd the last three years of data specic to crime and re safety
on our campus.
The men and women of the Bentley University Police Department are
highly trained and strongly dedicated to maintaining a safe campus
environment for all. We recognize that we cannot do it alone and the
best way to accomplish this, is through a collaborative effort by our
police department and our community members. Each of us must
assume an active role by reporting safety concerns, suspicious/criminal
activity, and taking precautions to prevent ourselves and others from
being victimized. Together, we can continue to maintain a very low
crime rate and the consequential feelings of safety and security.
I would encourage you to review the contents of our annual report.
If you have any questions or suggestions, feel free to contact me or
a member of my team. Stay safe and healthy!
Sincerely,
Francis G. Bourgeois
Chief of Police
From the
Chief of Police
NONDISCRIMINATION Bentley University does not discriminate in admission or access
to or treatment or employment in any of its educational programs or activities, including
scholarships, loans and athletics, on the basis of race, color, religion, sex, sexual orientation,
gender identity and/or expression, marital status, age, national origin, citizenship status,
disability, genetic information, military or veteran status. Bentley University maintains
and supports afrmative action plans for its workplace in compliance with federal law.
Equal opportunity extends to all aspects of the employment relationship, including hiring,
promotions, training, working conditions, compensation and benets. Bentley University’s
policies and practices reect the university’s commitment to nondiscrimination in all areas
of employment. The university complies with Title VI of the Civil Rights Act, Title IX of the
Education Amendments, Section 504 of the Rehabilitation Act and the Americans with
Disabilities Act, and Revenue Procedure 75-50 prohibiting such discrimination. Anyone
believing that he or she has experienced adverse treatment may register a complaint with
George Cangiano, Vice President and Equal Opportunity Ofcer, at 781-891-2640 or to the
Title IX coordinator, Elizabeth Humphries 781-891-2225.
2 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 3
Security Awareness and Crime Prevention
Drug and Alcohol Policies
Sexual Assault, Domestic/Dating Violence, Stalking Policies
Registered Sex Offender Information
Community Responsibility
Personal Safety Tips
Reporting Criminal Actions or Emergencies
Law Enforcement Authority and Interagency Relationships
Access to Campus Facilities
Maintenance and Security of Campus Facilities
Crime Reporting
Crime Denitions and Statistics
Criminal Offenses/Arrests and Referrals/Hate Crimes
Procedures for Missing Students Residing on Campus
Emergency Response and Evacuation Procedures
Annual Fire Safety Report
Evacuation Meeting Areas Map
Gender-Based Harassment and Discrimination Policy
Important Telephone Numbers
Police Call Box Map
Table of Contents
The information in this booklet is provided as part of the university’s
commitment to campus safety and security, and to meet compliance
standards set forth in the Jeanne Clery Disclosure of Campus Security Policy
and Campus Crime Statistics Act. Bentley University is an institution of
higher education containing one main campus of approximately 163 acres
within the Waltham, Massachusetts, city limits. Approximately 5,500
students are enrolled in courses at Bentley University, and 1,200 faculty and
staff support the institution.
Security Awareness and Crime Prevention
Like most other colleges, universities and municipalities, Bentley strives to be
proactive rather than reactive — to prevent crimes from occurring. A primary
vehicle for accomplishing this goal is the department’s crime prevention
program. Whenever possible, crime prevention programs are conducted in
concert with educational programs sponsored by university organizations.
The university’s crime prevention program takes a two-part approach to the
prevention of crime and criminal misconduct. It is designed to eliminate or
minimize opportunities for crime on campus, and to create an atmosphere in
which students and other community members become more responsible for
their own security and the security of others. Following is a list of programs
and services provided by the University Police Department to promote crime
prevention awareness.
EMERGENCY NOTIFICATIONS: In the case of a major crisis or catastrophic
event, Bentley can alert the community through an emergency notication
system that is capable of delivering information regarding the crisis and
providing instructions as to what steps to take to ensure safety. The system
allows for emergency notication via campus email, siren system, classroom
notications, and ofce, home, and cell phone numbers (including text
messaging). Alerts will also be posted on the Bentley website.
SAFETY ESCORT SERVICE: Members of the Bentley community may request
a safety escort from one campus location to another whenever there is a
concern for their safety and security on campus. Personal safety escorts are
available 24 hours a day and may be requested by calling the University Police
at 781-891-2201.
ONLINE NEW STUDENT AND PARENT ORIENTATION: Programs are
provided for students and parents to inform them of the services provided
by University Police.
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EMERGENCY TELEPHONES: Emergency and help phones are located both
inside campus buildings and in exterior locations to provide easy contact
with University Police for general assistance and emergencies.
VIDEO SURVEILLANCE: There are cameras at specic locations throughout
campus. Video is recorded and temporarily stored, and may be monitored in
real time by staff at the police station.
PERSONAL SAFETY PROGRAMS: These programs are provided by request to
any community member or group. Presentations offer helpful hints and self-
defense techniques using everyday items.
RAPE AGGRESSION DEFENSE (R.A.D.) TRAINING CLASSES: The University
Police Department has trained instructors certied to teach this unique
self-defense program. The R.A.D. program, specically designed for
women, offers self-defense tactics and training designed to assist women in
defending themselves against sexual assault.
RAPE AWARENESS, EDUCATION AND PREVENTION: In addition to the
R.A.D. program and in cooperation with numerous student organizations,
University Police delivers presentations on rape awareness, education and
prevention. Call 781-891-2201 for more information.
NEW EMPLOYEE ORIENTATION: All new
employees receive information regarding
re as well as general safety and security
measures on campus and information about
crime reporting required by Clery.
NEW STUDENT ORIENTATION: Held at
the beginning of each academic year, this
orientation promotes closer relationships
between the police and students. The
department coordinates this crime
prevention and community-building program
with the Division of Student Affairs.
RESIDENCE HALL SAFETY AND
SECURITY PROGRAMS: The University
Police Department works closely with the
Residential Center to ensure our residence
halls remain safe. All rst-year resident
students are required to attend a one-hour mandatory safety presentation
conducted by University Police ofcials during Orientation that covers an
array of topics regarding services provided by the University Police, re
safety policies, building egress procedures and general safety. Additionally,
the University Police Department may conduct safety presentations to
residents of specic residence halls at the request of Residential Center staff
should safety concerns or crime trends develop.
EMERGENCY MANAGEMENT GROUP: This committee meets monthly to
identify and address general safety issues on campus, and to review the
university’s response protocols in the event of a crisis. The committee is
comprised of various Bentley staff and faculty, including the Chief of Police
and is led by the University’s Emergency Manager.
COMMUNITY ENGAGEMENT TEAM: The University Police Department uses
a team of ofcers to make and maintain contacts with various organizations
throughout campus. As part of our effort to involve campus citizens in a
community–police partnership, the process began in the residence halls and
has been a successful way to promote community involvement in safety and
security issues.
BLUE – COMFORT DOG: Blue is a black lab certied by the AKC as a Canine
Partner to help community members in need of support. Blue and his
handler take requests to attend events on campus and please go say hello
when you see them out and about.
6 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 7
CPR AND STANDARD FIRST AID
TRAINING: This program is provided
by request to any group within the
university community. Though not
commonly associated with crime
or criminal activity on campus, the
program teaches self-sufciency and
concern for others.
Instructors are members of University
Police who are properly trained and
certied by the American Red Cross or
the American Heart Association.
PRINTED CRIME PREVENTION
MATERIALS: These are used to conduct
programs for students in the residence
halls or elsewhere on campus. Printed
brochures, posters and similar resources
are always on hand at the Callahan
Police Station.
SECURITY SURVEYS: Comprehensive security surveys are conducted when
a concern for security is identied. University Police ofcers trained in
conducting security surveys identify problems and recommend corrective
action to improve security on campus.
Drug and Alcohol Policies
In addition to maintaining strict compliance with all state and federal
laws, Bentley has its own drug and alcohol policies. The following acts are
prohibited on university premises or at Bentley-sponsored activities and
events: distribution, possession or use of any illegal drug and/or the use,
possession or distribution of any controlled substance or marijuana without
legal authorization; providing alcoholic beverages to individuals under 21
years of age; possession of alcoholic beverages by individuals under 21 years
of age; illegal possession of an open container of an alcoholic beverage; public
intoxication; driving while intoxicated; and drinking alcoholic beverages in
an unlicensed public place.
In addition to disciplinary sanctions imposed through university procedures,
including suspension or expulsion from the university, students and
employees may face criminal prosecution and imprisonment under federal
and state laws. The online Student Handbook lists details of felony and
misdemeanor crimes and subsequent disciplinary actions for students.
University employees may be disciplined under the Human Resources
process. Faculty and staff members are not excluded from prosecution under
federal and state laws merely by virtue of their employment.
Bentley recognizes that there are serious health risks associated with
the misuse and abuse of mind-altering drugs, including all controlled
substances and alcohol. These risks include, but are not limited to: physical
and psychological dependence; damage to the brain, pancreas, kidneys and
lungs; high blood pressure, heart attacks and strokes; ulcers; birth defects;
diminished immune system; and death. The Centers for Health, Counseling
& Wellness, and the Alcohol and Other Drug Resource Center provide
assessment and referral services to students. These same ofces serve as
informational and educational resources for alcohol and other drug-related
matters. Information about educational materials and programs offered is
available from the Centers for Health, Counseling & Wellness at 781-891-2222
or the Alcohol and Other Drug Resource Center at 781-891-2777. Assistance
for employees can be obtained through Human Resources or condentially
through the Employee Assistance Program at 800-648-9557.
Sexual Assault, Domestic/Dating Violence, Stalking Policies
This section applies to all incidents of sexual assault which include, rape,
fondling, incest, and statutory rape. It also applies to domestic or dating
violence and stalking incidents. Individuals are urged to report any of the
above incidents to University Police as soon as possible, regardless of where
the offense took place and whether or not the offender is known to the
individual reporting. University Police will work closely with the reporting
party to ensure appropriate medical care and counseling services are offered.
Police will also assist victims/survivors in notifying appropriate off-campus
law enforcement authorities, when applicable. University Police has male
and female ofcers specially trained in sexual assault investigation who are
available 24 hours a day. There are strict laws governing the protection of
a victim’s name during a criminal process, it will be kept private. Contact
University Police or the Director of Public Safety if you have any questions
about how to proceed with criminal prosecution.
We recognize the delicate nature of these types of incidents and the
difculty inherent in talking about them. Of utmost importance is the
emotional well-being of the victim. Resources are available to victims
through a number of on- and off-campus ofces. On campus University
Police, the Ofce of the Dean of Student Affairs, the Centers for Health,
Counseling & Wellness, Spiritual Life Center, or the Residential Center can
8 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 9
be contacted for support. See Gender-Based Harassment and Discrimination
Policy in this book for further information about accommodations that
can be made for survivors. All reporting parties will be given the Sexual
and Relationship Violence Resource Guide which includes both on and off
campus resources, options for reporting, accommodations that can be made,
and students’ rights under Title IX.
It is very difcult to know in the immediate aftermath of a sexual assault,
stalking, domestic or dating violence incident whether or not an individual
will want to pursue legal charges or seek an order of protection. Having
evidence collected does not commit an individual to reporting or prosecuting
the conduct; the evidence can be sent to the crime lab anonymously and
held for a period of fteen years. Physical evidence can usually be collected
up to ve days after an assault, though the likelihood of capturing evidence
decreases with time. Showering, urinating, and brushing teeth may destroy
evidence. Clothing and bedding may contain evidence and can be taken to
the Emergency Room in a paper bag (not plastic) or given to police. Drugs
used in sexual assaults often leave the body very quickly. Individuals
suspecting they may have been drugged should attempt to collect urine to
take to the ER if urination is necessary before arriving there. All electronic
evidence should be saved or otherwise preserved. This is especially
important in stalking cases. Witness statements will be requested for
prosecution, so giving those names to police, if an individual chooses to
report, will be important.
If an individual chooses to report one of the above crimes, there
are several options: University Police 781-891-2201, the Waltham Police
781-893-1212, or the Middlesex County District Attorney’s Ofce, located
at the Waltham District Court 781-897-8650. Cases can also be pursued
through the university’s judicial system via the Title IX Coordinator.
Please see the Gender-Based Harassment and Discrimination Policy
section of this book for further information regarding proceeding
through the University judicial system, potential sanctions for students
or employees, interim support measures, and accommodations.
Registered Sex Offender Information
In compliance with the Federal Campus Sex Crime Prevention Act, current
sex offender information for students or employees of the university can be
obtained through the Waltham Police Department Detective Unit, located
at 155 Lexington Street in Waltham. Additionally, level-three offender
information can be obtained from the Massachusetts Sex Offender Registry
Board website: www.mass.gov/orgs/sex-offender-registry-board then search
for offenders in the City of Waltham. If you have any questions, please call
the Bentley University Police Department at 781-891-2201.
Community Responsibility
The cooperation and involvement of students, faculty and staff in their own
safety and security is crucial to maintaining a safe campus environment. All
members of the Bentley community can assume responsibility for their own
safety and well-being, and the security of their belongings by taking simple,
common sense precautions. Bentley staff make every effort to protect,
serve and care for everyone in the community, but the university cannot
help those unwilling to help themselves. The Bentley University Police and
dispatchers hope that all members of the community form a partnership
built on mutual respect and cooperation, and through this partnership
ensure a safe and secure learning, living and working environment.
Personal Safety Tips
Although the Bentley campus is reasonably safe, crime can happen
anywhere and safety can be compromised at any time. No one set of
guidelines can completely protect you, but following the tips below can
minimize your chances of being victimized. You should always trust your
own instincts and follow the rules of common sense.
■ Do not prop open residence hall or apartment complex doors.
■ Be mindful of tailgating. Tailgating is following or walking closely behind
a resident/person into a secured or locked facility without permission
and without being identied. Attempts to do this should be reported to
University Police.
■ Do not allow door-to-door salespeople to enter your room. University
ordinances prohibit soliciting and the alleged salesperson may be
“casing” your room for later theft. This includes letting delivery people
into the building.
■ Lock your door when sleeping or showering.
■ Lock your door when you leave, regardless of the length of time you plan
to be gone.
■ Keep small items of value, such as wallets, money and jewelry, out of
plain view or in a security box.
■ Keep a record and photograph of all valuables noting descriptions and
serial numbers. You can also engrave all personal belongings, contact
University Police for additional information.
10 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 11
■ Report all thefts immediately to University Police at 781-891-2201.
■ Get to know others around you and watch out for each other.
■ Do not leave notes where anyone can read them stating where, when or
how long you will be gone on any electronic media messages, and do not
leave notes containing room combination numbers, ATM pin codes, or
computer passwords where others can see them.
■ Do not take in overnight guests whom you do not know.
■ Close your drapes and blinds at night.
■ Report all doors, locks and windows that are in need of repair to your
Resident Assistant as soon as possible
■ Always ask who is at the door before you open it and use the peephole.
■ Never give out your room combination or loan your Bentley ID card to
anyone else.
■ Notify professional staff if there are maintenance or lighting deciencies
that may compromise building security or make you feel less safe.
■ If you receive harassing or annoying phone calls, hang up right away with
no conversation, reaction or emotion. Then call University Police at
781-891-2201 to report it.
■ Do not invite people you “meet” on the Internet to your room or to stay
overnight in your room.
■ Watch out for your friends and fellow students/employees. If you see
someone who looks like they could be in trouble or needs help, ask if they
are ok and contact University Police if necessary.
■ Safely intervene when you notice people who seclude, hit on, try to make
out with or have sex with people who are incapacitated.
■ Speak up when someone discusses plans to take sexual advantage of
another person. If you have concern for another member of the Bentley
community, you can contact the University Police anonymous tip line
or ll out the care report form at bentley.edu/bentley-cares. If it is an
emergency call University Police at 781-891-3131.
■ Believe someone who discloses sexual assault, abusive behavior, or
experience with stalking and encourage them to consult resources on
campus, which can be found at bentley.edu/titleix.
■
Refer people to on- or off-campus resources listed in this document, along with
bentley.edu/titleix for support in health, counseling, or with legal assistance.
■ Communicate nonverbal cues that you are calm, condent, and know
where you are.
■ Cross streets using crosswalks and electronic walk signals.
■ Stay in well-lit, busy areas.
■ When using public transportation, follow these rules: use a busy, well-lit
bus stop, sit near the driver, and don’t sleep.
■ Don’t be afraid to tell someone who is harassing you to leave you alone
in a rm, loud voice.
■ Trust your instincts — if something or someone makes you uneasy, get
out or away.
■ Walk or jog with a companion.
■ Keep your car locked at all times.
■ Avoid ashing cash or valuables.
■ Have your key in hand as you approach your car, dorm or apartment.
■ Call University Police for a personal safety escort if you feel concerned for
your safety while on campus.
Reporting Criminal Actions or Emergencies
The Bentley University Police Department is responsible for campus law
enforcement, security and emergency response. It is the department’s
mission to provide a comprehensive program of law enforcement, security
and related public safety services to help ensure the campus remains a safe
and pleasant place in which to live, study and work. The Michael Callahan
Police Station headquarters is located on the main campus, on the hill at
the Beaver Street entrance. It is open and staffed 24 hours a day by trained
professional police, security and communication personnel. Members
of the Bentley University community are urged to immediately report
crimes, suspicious activity or other emergencies to the Bentley University
Police Department by calling 781-891-3131, and members of the University
Police Department will promptly respond. A cell phone app RAVE Guardian
can be used to call or text Bentley Police, access important documents or
phone numbers, and share tracking information for safe travel. To obtain
information or request security services, community members should call
the University Police business line at 781-891-2201. All phone lines routed
to University Police are staffed 24 hours a day. Crimes can also be reported
anonymously or condentially by lling out and submitting the form
provided on the University Police website bentley.edu/police. Well-marked red
emergency phones are located throughout the interiors of campus buildings
in the academic area of the university. Well-marked yellow emergency phones
are located throughout the common corridors of residence halls. These phones
directly connect the caller to the University Police dispatcher and can be used
12 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 13
state and federal law enforcement agencies and all appropriate segments
of the criminal justice system. While there is no written memorandum
of understanding with Waltham Police, there is frequent communication
between the Chiefs of the departments to ensure our continued working
relationship. Crime reports and information are exchanged on a routine
basis, including information provided by Waltham Police regarding all
reports involving Bentley students.
Various members of University Police participate actively in professional
associations that enhance their prociency in areas specic to their work
responsibilities. Members of the department maintain active membership in
the International Association of Campus Law Enforcement Administrators,
the Northeast Colleges and Universities Security Association, the
Massachusetts Association of Campus Law Enforcement Administrators,
the American Society for Industrial Security, the Massachusetts Chiefs of
Police Association, the International Association of Chiefs of Police, the
Massachusetts Police Accreditation Commission and the Massachusetts
Crime Prevention Ofcers Association.
to report police, re or medical emergencies. In addition to the red emergency
phones, there are a number of beige courtesy phones inside campus buildings
that can be used to contact University Police for general business inquiries and
non-emergency service requests. These phones can also be used to connect
to any other campus phone. If you wish to contact University Police from the
courtesy phones, simply dial extension 2201.
Exterior “help” phones with emergency direct-dial service to University
Police are also located near entrances of buildings throughout the campus
beneath large, blue reective “Help” signs. Help phones at the exteriors of
residence halls not only allow for emergency calls to the University Police
but also allow users to dial a friend for access to a particular hall, and are
free of charge to anyone seeking information or assistance. Labels bearing
the University Police business, snow information, and emergency phone
numbers are placed on all of the phones described above. These numbers
are also found on publications printed by the University Police, as well as in
the campus phone directory. The University Police Department maintains
both direct telephone and two-way radio contact with the Waltham Police
Department. University Police also has direct radio service with the
Waltham Fire Department and local ambulance service through the city of
Waltham’s 911 system.
Law Enforcement Authority and Interagency Relationships
University Police ofcers are commissioned in accordance with the
provisions of Chapter 22C Section 63 of the Massachusetts General Laws.
They have full law enforcement authority, including arrest powers, in and
upon all property owned, occupied or used by the Bentley community.
All University Police ofcers are graduates of a police academy conducted
and sanctioned by the Massachusetts State Police or the Massachusetts
Municipal Police Training Committee. Police ofcer recruit training
academies comprise several months of in-depth training in all aspects of
law enforcement, followed by several weeks of eld training under the close
supervision of a qualied Police Field Training Ofcer. In addition to formal
law enforcement training, Bentley police ofcers are provided with training
specic to campus law enforcement issues to enhance their ability to provide
the best service possible to the campus community. Annual in-service
training is provided to all ofcers, and they are frequently assigned to
specialized training programs to enhance their professional development.
The University Police Department maintains excellent working relationships
with the Waltham Police Department, the Middlesex County District
Attorney’s Ofce, the Massachusetts State Police, other local, campus,
14 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 15
Access to Campus Facilities
With the exception of residence halls, most campus buildings and facilities are
accessible to members of the campus community, guests and visitors during
normal hours of business, and during designated hours on weekends and holidays
depending on the variety of events and activities taking place on campus. Once
buildings are secured, people requiring access to academic or administrative
buildings on campus must contact University Police at 781-891-2201 to be informed
of the access requirements established by the university.
Exterior doors to all residence halls remain locked 24 hours a day. Access
to residence halls is controlled by electronic card readers; unlimited access
is available to all authorized resident students via their Bentley ID card.
Guests and visitors who wish to enter residence halls should call their
hosts or contact the Residential Center or University Police for assistance.
All residence halls are equipped with door security cameras and intrusion
alarms that detect unauthorized access and doors that are propped open.
These alarms are monitored at University Police headquarters; University
Police ofcers are dispatched to investigate any reported alarm violations.
Maintenance and Security of Campus Facilities
Bentley maintains a strong commitment to safety and security. Exterior
lighting is an important component of keeping the campus safe. Motor
vehicle parking lots, pedestrian walkways and building exteriors are well
lighted. Members of the university community are strongly encouraged
to always use designated walkways, pathways and crosswalks both
on and off campus for their safety. The University Police and Facilities
Management staff routinely conduct inspections and surveys of exterior
lighting on campus to identify lighting problems. The Facilities Management
Department gives high priority to maintenance of exterior lights in need of
repair or replacement.
More serious maintenance problems are rectied immediately through an
emergency notication system maintained between University Police and
the Facilities Management trades supervisors. This system provides for the
response of Facilities Management tradespeople 24 hours a day. Members of
the campus community are encouraged to report any maintenance concerns
to Work Order Control at 781-891-2208 during regular business hours or the
University Police Department at 781-891-2201 after hours.
As a part of routine and directed patrols, University Police Department
personnel inspect exterior doors on campus facilities. Doors are checked
to ensure that their automatic closing and locking units are working
properly. Exterior doors on all campus academic and administrative
buildings are locked and secured each evening by campus police and/or
campus security ofcers from the University Police Department. These
ofcers also report door and security hardware operating deciencies to
ensure prompt repairs are made.
Many parking lots and public areas of the campus are routinely monitored by
closed-circuit cameras. These cameras forward their pictures to the display and
control screens located in the University Police Department’s communications
area. Communications specialists routinely use the closed-circuit television
system to identify problems that may require a police response.
Parking lots and public areas on campus are regularly patrolled by campus
police and campus security ofcers.
Crime Reporting
Bentley makes every effort to keep the community informed about crime
and crime-related problems. The university’s duty to inform is taken very
seriously. As a result, information related to crime and criminal activity is
provided to the community in an accurate and timely fashion. Notication
efforts and methods include, but are not limited to, the initiatives listed below.
ANNUAL CAMPUS SECURITY AND FIRE SAFETY REPORT: A comprehensive
annual report of crime-related information is compiled, published and
available online. The report is also available by request.
PUBLIC LOG: The University Police Department prepares and maintains an
incident log for public viewing. This log is available for inspection during
regular business hours.
CLERY LOG: The University Police Department prepares and maintains an
incident log of all crimes committed on, or near, campus. This log is available
to anyone who requests to view it.
RESIDENCE HALL CRIME PREVENTION PROGRAMS: Each residence hall
program features an overview of how students can help in the prevention of
crime. These programs are done in conjunction with Residential Center staff
and address issues to enhance students’ overall security awareness.
TIMELY WARNING NOTICES: University Police provide timely warning
notices to the community, that withhold the names of victims as
condential, and that will aid in the prevention of similar occurrences,
whenever an incident is considered by the university to represent a threat
16 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 17
to the community. Notices will be made using our emergency notication
system and/or campus email.
Crime Denitions and Statistics
Convinced that an informed public is a safety-conscious public, Bentley
gladly provides all information related to the safety and security of the
campus community. The university willingly complies with all laws
pertaining to the reporting of crime and the public’s right to information.
Bentley also maintains strict compliance with the privacy act, Buckley
Amendment, and all other laws governing the release of personal
information. Personally identifying information of victims is not included
in publicly available logs. In accordance with the Jeanne Clery Disclosure
of Campus Security Policy and Campus Crime Statistics Act, the following
denitions and statistics are provided for your information. They are
a compilation of the crimes (listed below) reported to Waltham Police,
Bentley Police, or any Bentley Campus Security Authority. CSAs include
any member of the Bentley University Police Department, any individual
who has responsibility for security, but who is not a member of the Police
Department, any individual identied by the University as someone to whom
a crime should be reported; and any University ofcial who has signicant
responsibility for student and campus activities. Individuals who fall under
this denition may vary among departments and areas. The following are
examples of CSAs, but not an exhaustive list:
■ All Student Affairs staff members, including Vice President for Student
Affairs/Dean of Students, Title IX Coordinator, all staff from the
Residential Center, staff from the Health, Wellness, and Counseling
Centers, and Athletics staff
■ Staff from the Cronin Center for International Education
■ Staff from Graduate and Undergraduate Academic Services
Crime statistics are collected and reported in accordance with the University
Police Clery Reporting Procedure. If you have questions concerning these
statistics or campus safety in general, contact the Director of Public Safety.
All crimes are listed in the Clery Crime Log, however, only the following
crimes are reported annually in this report.
MURDER/NON-NEGLIGENT MANSLAUGHTER: Dened as willful killing of
one human being by another.
MANSLAUGHTER BY NEGLIGENCE: Dened as the killing of another person
through gross negligence.
SEXUAL ASSAULT: Under the Violence Against Women Act (VAWA), the
denition of sexual assault is an offense that meets the denition of rape,
fondling, incest, or statutory rape as used in the FBI’s Uniform Crime
Reporting (UCR) program. Per the National Incident-based Reporting System
User Manual from the FBI UCR Program, a sex offense is “any sexual act
directed against another person without the consent of the victim, including
instances where the victim is incapable of giving consent.”
RAPE: The penetration, no matter how slight, of the vagina or anus with any
body part or object, or oral penetration by a sex organ of another person,
without the consent of the victim.
Massachusetts denes Rape as sexual intercourse or unnatural sexual
intercourse with a person against his will, by force or threat of bodily injury.
FONDLING: The touching of the private parts of another person for the
purpose of sexual gratication, without the consent of the victim, including
instances where the victim is incapable of giving consent because of his/her
age or because of his/her temporary or permanent mental incapacity.
Massachusetts denes Indecent Assault and Battery on a person age 14 or
over as indecent assault and battery against a person’s will. An indecent act
is one that is fundamentally offensive to contemporary standards of decency.
An assault and battery may be “indecent” if it involves touching portions of
the anatomy commonly thought private, such as a person’s genital area or
buttocks, or the breasts of a female.
INCEST: Sexual intercourse between persons who are related to each other
within the degrees wherein marriage is prohibited by law.
Massachusetts denes Incest as persons within degrees of consanguinity
within which marriages are prohibited or declared by law to be incestuous
and void, who intermarry or have sexual intercourse with each other, or
who engage in sexual activities with each other, including but not limited to,
oral or anal intercourse, fellatio, cunnilingus, or other penetration of a part
of a person’s body or insertion of an object into the genital or anal opening
of another person’s body, or the manual manipulation of the genitalia of
another person’s body.
STATUTORY RAPE: Sexual intercourse with a person who is under the
statutory age of consent.
Massachusetts denes Statutory Rape as unlawful natural or unnatural
sexual intercourse with a person under 16 years of age.
ROBBERY: Dened as taking or attempting to take anything of value from
18 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 19
Per Massachusetts statute
above, dating violence is
included in the denition
of domestic violence.
STALKING: The VAWA
denition of stalking is
engaging in a course of
conduct directed at a
specic person that would
cause a reasonable person
to (a) fear for the person’s
safety or the safety
of others; or (b) suffer
substantial emotional
distress.
For purposes of this
denition- (a) Course of
conduct means two or
more acts, including,
but not limited to, acts
which the stalker directly,
indirectly, or through
third parties, by an action,
method, device, or means follows, monitors, observes, surveils, threatens,
or communicates to or about a person, or interferes with the person’s
property. (b) Reasonable person means a reasonable person under similar
circumstances and with similar identities to the victim. (c) Substantial
emotional distress means signicant mental suffering or anguish that may,
but does not necessarily, require medical or other professional treatment or
counseling.
Massachusetts denes stalking as willfully and maliciously engaging in a
knowing pattern of conduct or series of acts over a period of time directed at
a specic person which seriously alarms or annoys that person and would
cause a reasonable person to suffer substantial emotional distress, and
making a threat with the intent to place the person in imminent fear of death
or bodily injury.
LARCEN Y-THEFT: The unlawful taking, carrying, leading, or riding away of
property from the possession or constructive possession of another.
SIMPLE ASSAULT: An unlawful physical attack by one person upon another
where neither the offender displays a weapon, nor the victim suffers obvious
the car, custody, or control of a person or persons by force or threat of force or
violence and/or by putting the victim in fear.
AGGR AVATED ASSAULT: Dened as an unlawful attack by one person upon
another for the purpose of inicting severe or aggravated bodily injury. This
type of assault usually is accompanied by the use of a weapon or by means
likely to produce death or great bodily harm.
BURGLARY: Unlawful entry of a structure to commit a felony or a theft.
MOTOR VEHICLE THEFT: Theft or attempted theft of a motor vehicle.
ARSON: Any willful or malicious burning or attempt to burn, with or without
intent to defraud, a dwelling house, public building, motor vehicle or aircraft,
personal property of another, etc.
DOMESTIC VIOLENCE: Includes felony or misdemeanor crimes of violence
committed by a current or former spouse or intimate partner of the victim,
by a person with whom the victim shares a child in common, by a person
cohabitating with or has cohabitated with the victim as a spouse, by a person
similarly situated to a spouse of the victim under the domestic or family
laws of the Commonwealth of Massachusetts, or by any other person against
an adult or youth victim who is protected from the person’s acts under the
domestic or family violence laws of the jurisdiction.
Massachusetts law denes domestic violence as an assault or assault and
battery on a household or family member. Household or family member is
dened as persons who (i) are or were married to one another, (ii) have a child
in common regardless of whether they have ever married or lived together
or (iii) are or have been in a substantive dating or engagement relationship;
provided, that the trier of fact shall determine whether a relationship is
substantive by considering the following factors: the length of time of the
relationship; the type of relationship; the frequency of interaction between
the parties; whether the relationship was terminated by either person; and
the length of time elapsed since the termination of the relationship.
DATING VIOLENCE: The VAWA denition of dating violence is violence
committed by a person who is or has been in a social relationship of a
romantic or intimate nature with the victim. The existence of such a
relationship shall be based on the reporting party’s statement and with
consideration of the length of the relationship, the type of relationship,
and the frequency of interaction between the persons involved in the
relationship. For purposes of this denition, dating violence includes, but is
not limited to, sexual or physical abuse or the threat of such abuse.
20 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 21
severe or aggravated bodily injury involving apparent broken bones, loss of
teeth, possible internal injury, severe laceration, or loss of consciousness.
INTIMIDATION: To unlawfully place another person in reasonable fear of bodily
harm through the use of threatening words and/or other conduct, but without
displaying a weapon or subjecting the victim to actual physical attack.
VANDALISM: To willfully or maliciously destroy, damage, deface, or
otherwise injure real or personal property without the consent of the owner
or the person having custody or control of it.
LIQUOR LAWS: The violation of state and/or local laws or ordinances
prohibiting the manufacture, sale, purchase, transportation, possession or
use of alcoholic beverages.
DRUG VIOLATIONS: The violation of laws prohibiting the production,
distribution, and/or use of certain controlled substances and the equipment
or devices used in their preparation and or use.
WEAPONS LAW VIOLATION: The violation of laws or ordinances prohibiting
the manufacture, sale, purchase, transportation, possession, concealment,
or use of rearms, cutting instruments, explosives, incendiary devices, or
other deadly weapons.
Bentley University will, upon written request, disclose to the alleged victim
of a crime of violence or a non-forcible sex offense, the report on the results
of any disciplinary proceeding conducted by the institution against a student
who is the alleged perpetrator of such crime or offense. If the alleged victim
is deceased as a result of such crime or offense, the next of kin of such victim
shall be treated as the alleged victim for purposes of this paragraph.
Criminal Offenses 2018 to 2020
UCR CRIMINAL OFFENSES 2018 TO 2020
CRIMINAL OFFENSES
ON CAMPUS
Type Of Offense Year
Non
Residential
Facility
Residential
Facility
Total On
Campus
Non Campus
Building or
Property
Public
Property
Totals Unfounded
MURDER/ 2020 0 0 0 0 0 0 0
NON-NEGLIGENT 2019 0 0 0 0 0 0 0
MANSLAUGHTER 2018 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
MANSLAUGHTER BY 2019 0 0 0 0 0 0 0
NEGLIGENCE 2018 0 0 0 0 0 0 0
2020 0 5 5 0 0 5 0
Rape * 2019 0 3 3 0 0 3 0
2018 0 7 7 0 0 7 0
2020 0 4 4 0 0 4 0
Fondling 2019 1 1 2 0 0 2 0
2018 0 7 7 0 0 7 0
2020 0 0 0 0 0 0 0
Incest 2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
Statutory Rape 2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
Robbery 2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
2020 0 1 1 0 0 1 0
Aggravated Assault 2019 4 1 5 0 0 5 0
2018 1 1 2 0 0 2 0
2020 0 2 2 0 0 2 0
Burglary 2019 0 2 2 0 0 2 0
2018 0 2 2 0 0 2 1
2020 0 0 0 0 0 0 0
Motor Vehi cl e Theft 2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
Arson 2019 0 0 0 0 0 0 0
2018 0 2 2 0 0 2 0
2020 0 1 1 0 0 1 0
Domesti c Viol ence 2019 0 2 2 0 0 2 0
2018 1 3 4 0 0 4 0
2020 0 0 0 0 0 0 0
Dating Violence 2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
Stalking 2019 1 4 5 0 0 5 0
2018 2 3 5 0 0 5 0
* Though not required to be reported, in the spirit of The Clery Act, we are disclosing that there was one additional rape reported in 2019
and one in 2020. They both occurred at private residences near campus and each involved two students.
22 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 23
Arrests and Referrals 2018 to 2020
Hate Crimes 2018 to 2020
2020
There were no Hate Crimes reported
2019
1 Intimidation in Non-Residence, On Campus, bias Religion
2018
There were no Hate Crimes reported
Procedures for Missing Students Residing on Campus
If a member of the university community has reason to believe that a
student who resides in on-campus housing is missing, the Bentley University
Police should be notied. The Bentley University Police will generate an
incident report and initiate an investigation in order to attempt to locate
the missing student using a wide range of electronic resources as well as
making personal contact with friends, classmates, co-workers and relatives.
If University Police determines that a student is missing and has been
missing for more than 24 hours, the Waltham Police Department, the police
department of the community where the missing student maintains a home
of record, and the person designated as the student’s missing student contact
will be notied no later than 24 hours after the student is determined to have
been missing for 24 hours. If the missing student is under the age of 18 and is
not an emancipated individual, Bentley University will notify the student’s
parent or legal guardian immediately after University Police has determined
that the student has been missing for more than 24 hours.
In addition to registering the name of a person as an emergency contact,
students residing in on-campus housing have the option to identify an
individual to be contacted by Bentley in the event the student is determined
to be missing for more than 24 hours. If a student has identied such an
individual, Bentley will notify that individual no later than 24 hours after the
student is determined to have been missing for 24 hours. Students who wish
to identify a contact for this purpose can do so through the semester housing
check in process or by contacting the Residential Center. This contact
information will be registered condentially and will be accessible only to
authorized campus ofcials and law enforcement and may not be disclosed
outside of a missing person investigation.
ARREST AND REFERRALS 2018 TO 2020
ARRESTS
ON CAMPUS
CRIME YEAR
Non
Residential
Facility
Residential
Facility
Total On
Campus
Non Campus
Building or
Property
Public
Property
Totals Unfounded
LIQUOR LAW VIO 2020
0 0 0 0 0 0 0
2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
DRUG VIOLATION 2020 0 0 0 0 0 0 0
2019 0 0 0 0 0 0 0
2018 2 0 2 0 0 2 0
WEAPON VIOL ATION 2020 0 0 0 0 0 0 0
2019 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0
JUDICI AL REFERRAL S
ON CAMPUS
CRIME YEAR
Non
Residential
Facility
Residential
Facility
Total On
Campus
Non Campus
Building or
Property
Public
Property
Totals Unfounded
LIQUOR LAW VIO 2020 13 160 173 0 0 173 0
2019 19 153 172 0 0 172 0
2018 18 231 249 0 0 249 0
DRUG VIOLATION 2020 4 21 25 0 0 25 0
2019 4 53 57 0 0 57 0
2018 9 101 110 0 0 110 0
WEAPON VIOL ATION 2020 0 0 0 0 0 0 0
2019 0 0 0 0 0 0 0
2018 0 1 1 0 0 1 0
24 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 25
Emergency Response and Evacuation Procedures
In the event of a signicant emergency or dangerous situation involving an
immediate threat to the health or safety of the Bentley community, Bentley
University Police will send an emergency alert notication utilizing the
Bentley Emergency Notication System. For less emergent but still serious
notications, the University may choose to send a campus wide email and/
or post notices in affected areas. Based on the nature of the emergency, the
responsibility for assessing the severity of the threat begins with the senior
staff of University Police, Student Affairs, The Centers for Health, Counseling,
and Wellness, Facilities Management and/or Risk Management. Once the
threat is conrmed, the decision regarding emergency notication will be
made by members of the Emergency Management Team. They will determine
the content of the notication, and the notication will be sent, without delay,
taking into account the safety of the community unless issuing a notication
will, in the professional judgement of responsible authorities, compromise
efforts to assist a victim or to contain, respond to, or otherwise mitigate the
emergency. The emergency notication system utilizes email, text messaging,
telephone voice messaging, sirens, and classroom notications to alert
the community. Emergency messages are also posted on the home page of
the Bentley website. Messages will be sent to all community members in
the affected area and will contain only a very brief description of the type
of emergency along with instructions for self-protection. It is critical that
community members follow the instructions immediately. After the initial
alert message, additional information may be distributed by means of another
alert message, by email, or by web at bentley.edu and bentley.edu/emergency.
If an emergency will affect the greater community, Waltham Police will be
alerted to contact campus neighbors. Parents and community members can
access bentley.edu/emergency for information.
YOU MUST PROVIDE YOUR CONTACT INFORMATION TO BE INCLUDED
IN THE EMERGENCY NOTIFICATION SYSTEM. Members of the Bentley
community are invited to provide or update their contact information at the
beginning of each semester, or may update their contact information at any
time by logging into Workday and clicking Change Contact Information.”
A full-scale test of the Bentley emergency notication system is performed
during the fall and spring semesters, and members of the Bentley
community will be informed of at least one annual test date in advance by
email. On some occasions, the test will be unannounced. Documentation
of the tests performed, including a description of the exercise, the date and
time, and whether it was announced or unannounced, is kept on le at the
University Police Department.
In the event it becomes necessary to evacuate a building, the re alarm
system, or in some buildings a public announcement system, may be used
to notify occupants. When the re alarm sounds, building occupants should
proceed quickly and calmly to the nearest exit, or follow the instructions
provided over the announcement system. Always bring essentials with you
such as a purse, keys, or jacket since you could be displaced from the building
for an extended period of time. Do not use elevators. It is recommended
that you familiarize yourself with two means of exit from areas where you
routinely work, live or study. Remain outside the building until a public safety
ofcial authorizes reentry or directs you to an alternate location should the
building need to be evacuated for an extended period of time.
26 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 27
of the device. Do not tamper with any associated components of the water
sprinkler re suppression system.
Smoke Detectors
All residence halls are equipped with addressable re alarm systems. When
a device is activated or tampered with, a signal with the device location is
sent to the re alarm panel and to University Police. All detectors on campus
are hard-wired to the main and backup electrical systems for their buildings.
Tampering with a smoke detector is a violation of University judicial policies
and could result in an electrical shock.
There are two types of alarms: supervisory and
general. A supervisory alarm rings the alarms
in the apartment where a smoke detector is
activated. A general alarm rings the alarms in
the entire building. Both signals are received by
University Police who investigate all re alarm
signals. A general alarm will cause a signal to
transmit to the Waltham Fire Department.
Tampering with or damaging any re safety
systems is a serious offense and can result
in criminal prosecution and/or university
disciplinary action.
Apartments and Suites
ORCHARDS, RHODES, FENWAY, COPLEYS, FOREST, KRESGE, FALCONE
COMPLEX, AND NORTH CAMPUS APARTMENTS: Each bedroom and living
room has a smoke detector. If one smoke detector is activated (causing a local
alarm) the alarms in the apartment will ring and University Police will be
notied. When the smoke condition clears, the alarm will silence by itself. If
two smoke detectors are activated within an apartment or suite, the general
alarm will ring for the building. This will cause University Police to respond
along with the Waltham Fire Department.
The hallways are also equipped with smoke detectors. If one hallway or other
common area (including lounges and study areas) is activated, the general
alarm for the building will be activated.
COLLINS AND BOYLSTON: Each bedroom has a smoke detector. If one smoke
detector is activated (causing a local alarm) the alarms in the apartment will
ring and University Police will be notied. When the smoke condition clears,
Annual Fire Safety Report
Fire Safety in Residence Halls
The University through its Manger of Life Safety, administers a program
of regular inspection, testing and maintenance of university premises to
ensure compliance with applicable re and life safety codes and standards.
This includes conducting regular evacuation drills and offering a variety of
educational and training programs in re safety and prevention techniques
for students, faculty and staff. All residence halls exceed local, state, and
national re safety codes and are equipped with modern re detection,
alarm, and suppression systems.
Reporting a Fire
If you discover or suspect a re, activate the nearest re alarm pull station
and leave the building or area immediately. To activate the re alarm, you
must both pull the tamper cover and pull the lever. After activating the
alarm, call University Police at 781-891-3131 or go to the nearest emergency
help telephone that is a safe distance from the re source to be connected to
University Police. Provide the dispatcher with the specic location of the re
and any other pertinent information.
REMEMBER:
■ Pulling the tamper cover to gain access to the re alarm pull station
will activate the tamper alarm only and will not report the alarm to
University Police.
■ After pulling the tamper cover, you must pull the lever on the re alarm.
By doing so, the building alarm will sound, alerting University Police and
the Waltham Fire Department of the situation.
Fire Suppression Systems
All residence halls are equipped with automatic re sprinkler systems. The
system is comprised of sprinkler heads, associated piping, controls, and
water under pressure. In the event of a re, the sprinkler heads are designed
to activate at a predetermined temperature. Do not hang items or material
from the sprinkler head, as this may activate or interrupt the spray pattern
28 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 29
the alarm will silence by itself. If two smoke detectors are activated within an
apartment, the general alarm will ring for the building. This will cause University
Police to respond immediately, followed by Waltham Fire Department.
A heat detector is located in each living room near the kitchen. They react
to sudden and rapid changes in temperature over a specic time period or a
high heat build-up. If this detector is activated, then the general alarm for the
building will be activated and University Police will respond immediately.
The hallways are also equipped with smoke detectors. If one hallway or other
common area (including lounges and study areas) is activated, the general
alarm for the building will be activated.
Dormitories and Special Housing
SLADE, MILLER, TREES, STRATTON, CAPE AND CASTLE: All bedrooms
and common areas (lounges, hallways, and study areas) are equipped with
smoke detectors. If one smoke detector is activated, the general alarm
will ring for the building. This will cause University Police to respond
immediately, followed by Waltham Fire Department.
Preventing Fires
COOKING: All cooking appliances, except microwave ovens, are prohibited from
suites and dormitory rooms. This includes hotplates, hotpots, toaster ovens,
popcorn poppers, and any other appliances whatsoever. Apartments may have
cooking appliances in the kitchen only. Cooking is allowed only in apartments
and residence hall kitchens. When cooking, remember the following:
■ Keep ovens clean at all times.
■ Turn on smoke exhaust fans when cooking.
■ Do not leave the oven or other heat-producing appliances unattended
while they are in operation.
■ Use only U.L. listed appliances.
■ If a pan of grease or a deep-fat fryer catches on re, immediately turn
off the heat, cover the burning pan with a lid if possible and, if available,
throw baking soda into the ame. Do not try to extinguish the re with
water, our, sugar or other materials. Never try to carry a cooking utensil
with burning liquid.
■ Do not open the door of your apartment or residence hall kitchen to clear
cooking smoke. Instead, open a window. Otherwise you will set off the
hallway smoke detectors and create a false alarm.
SPACE HEATERS: Space heaters are not allowed in any residence halls.
In an emergency situation only, Facilities Management will provide an
approved space heater for temporary heating purposes.
Additional Fire Prevention Guidelines
■ Plug all types of multiple plug adapters directly into wall outlets. Do not
use more than two extension cords in a single multiple-plug adapter.
Check cords for wear and have faulty appliances repaired or removed
from the residence.
■ Halogen lamps and neon signs are prohibited, even if they are non-
functional.
■ Do not drape any type of combustible material over lamps or other
electrical xtures.
■ Flammable and combustible liquids are prohibited in all residence halls.
This includes charcoal briquettes, lighter uids, gasoline, benzene,
propane, alcohol, cleaning uids, oil-based paints and thinners.
■ Do not use ammable decorations at any time, including during the
holiday season. Live trees or combustible ornaments are not permitted.
This includes cardboard cut-outs from boxes.
■ Combustible waste should be disposed of as soon as possible. Trash
and garbage should be emptied in the proper refuse containers, not left
in corridors or hallways since this may obstruct building egress. Limit
room trash collection to a maximum of one 12-pack sized box of mixed
recyclables and two kitchen-size trash bags or one large trash bag.
Accumulations larger than this are not allowed.
■ All types of open ames including candles and incense are strictly
prohibited in all campus buildings.
■ Do not hang any items from the ceiling as they may interfere with the
designed spray pattern of the sprinkler system or the path of heat and
smoke to a re detection device.
■ Room furnishings should not obstruct or hamper any access to an exit.
All doors must be able to swing freely in their full range of motion.
■ Do not prop open re doors. Closed re doors are designed to prevent
smoke and re from spreading.
■ Bicycles chained to stairways or landings are prohibited and will be
removed.
■ Motorcycles, mopeds, gasoline engines, engine parts or any ammable
fuels are prohibited in all campus buildings.
30 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 31
Smoking Policy
Smoking (including cigarettes, cigars, pipes, e-cigarettes, and any other
smoke-producing tobacco products) is prohibited on all properties owned
or leased by Bentley. This policy applies to students, faculty, staff, guests,
visitors, and contractors. Campus property includes (but is not limited
to): all interior space on campus and property leased by the university,
all outside property or grounds including walkways, breezeways, patios,
and parking lots — including vehicles, all outside property leased by the
University, all vehicles leased or owned by the University and all indoor and
outdoor athletic facilities.
Escaping From a Fire
When the re alarm sounds, prepare to exit immediately. Touch your door to
test its temperature. If it is hot, put towels or clothing around the door frame
to prevent smoke from entering. Open your window and wave something
white to attract attention.
If the door is cool, evacuate your room as soon as possible. Go to the nearest
exit. DO NOT WAIT for a staff person to tell you to leave. It is your responsibility
to evacuate the building in a quick and orderly fashion! If there is smoke in the
hall, stay low and proceed to the nearest exit. There are two exits on every oor.
Do not panic if one of the exits is blocked, proceed to the next one.
■ Stay calm. Do not run or shout.
■ Do not use an elevator. In the event that you are in an elevator when the
alarm sounds, it will bring you to the main oor.
It is essential to determine which residents have safely escaped. You should
assemble in designated spot for the building you are evacuating from.
Evacuation locations are noted on the map at the end of this section. Do
not attempt to re-enter the building until the Fire Department or University
Police has declared the emergency over.
Fire Drills
Fire drills are conducted each semester to familiarize everyone with the
sound of the alarms, building evacuation routes and designated gathering
spots outside the building. Use the emergency exit locations to evacuate the
building safely. Failure to evacuate when the re alarm sounds is not only
dangerous but punishable by a ne and/or other disciplinary action.
Fire extinguishers are located in all campus buildings. These are to be used
only for their intended purpose, and should not be removed at any other
time. Extinguishers are to be used only by trained personnel.
Fire Safety Education and Training
A re safety education program is presented during the rst week of classes
for all incoming rst-year resident students. Attendance at this presentation
is mandatory. Procedures to follow in the event of a re alarm are reviewed,
as well as the re safety policies that are in effect in the residence halls.
Plans for Future Improvements in Fire Safety
Bentley University intends to remain on task with regard to its prevention
strategies (education, inspections, re drills and device maintenance), and will
continue to upgrade re alarm systems throughout the campus. A deferred
maintenance program replaces or upgrades existing re alarm systems that
are approaching their service life expectancy. Whenever buildings undergo
major renovations, the life safety systems, re detection and re suppression
systems are replaced with current code compliant systems.
32 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 33
Bentley University Annual Fire Report
2018 to 2020
BENTLEY UNIVERSITY ANNUAL FIRE REPORT
2018 - 2020
Residential Building
Name
2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020 2018 2019 2020
Alder Hall
385 Beaver St
Birch Hall
385 Beaver St
Boylston A 385
Beaver St
Boylston B 385
Beaver St
1 1 6/7/20 1630 Unintentional Cooking 0 0 $0 20-00170
Cape House 500
Beaver St
Castle House 500
Beaver St
Cedar Hall
385 Beaver St
Collins Hall 385
Beaver St
1 1 2/10/19 2037 Unintentional Electrical 0 0 $3,140 19-00099
Copley North
500 Beaver St
1 1 5/8/19 0027 Unintentional
Heating
Equipment
0 0 $306 19-00352
Copley South
500 Beaver St
Elm Hall
385 Beaver St
Falcone East
385 Beaver St
Falcone North 385
Beaver St
Falcone West
385 Beaver St
Fenway Apts.
500 Beaver St
Forest Hall 385
Beaver St
Kresge Hall
385 Beaver St
1 1 2/19/18 0420 Intentional
Open
Flames
0 0 $50 18-00129
Maple Hall
385 Beaver St
Miller Hall
385 Beaver St
North Campus A
371 Forest St
1 1 3/172018 1843 Unintentional Cooking 0 0 $0 18-00186
North Campus B
371 Forest St
North Campus C
371 Forest St
North Campus D
371 Forest St
Oak Hall
385 Beaver St
Orchard North
500 Beaver St
1 1 1 1 10/24/18 4/13/20 1835 1904 Unintentional Unintentional Cooking Cooking 0 0 0 0 $0 $0 18-00628 20-00159
Orchard South
500 Beaver St
1 1 6/12/18 1519 Unintentional Cooking 0 0 $0 18-00358
Rhodes Hall 385
Beaver St
Slade Hall
385 Beaver St
1 1 2/3/18 2200 Intentional
Open
Flames
0 0 $25 18-00073
Spruce Hall
385 Beaver St
Stratton House
357 Beaver St
TOTALS 5 2 2 0 0 0 0 0 0 $75 $3,446 $0
Total Fires in Bldg Time of Fire Category Cause of Fire
Number of Injuries
Requiring Treatment at
Medical Facility
Number of Deaths
Value Of Property Damage
Caused by Fire
Case NumberFire Number Date of Fire
34 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 35
Bentley University Fire Safety System
2018 to 2020
BENTLEY UNIVERSITY FIRE SAFETY SYSTEM
Residential
Building
Name
Fire Alarm
Device On Site
Monitored By
Bentley Police
Full
Sprinkler
Smoke
Detectors
Bedrooms
Attic He at
Detectors
Number of
Evacuation
Test/Drills
2018
Alder Hall X X X X 2
Birch Hall X X X X 2
Boylston A X X X X 2
Boylston B X X X X 2
Cape House X X X N/A 2
Castle House X X X N/A 2
Cedar Hall X X X X 2
Collins Hall X X X X 2
Copley North X X X X 2
Copley South X X X X 2
Elm Hall X X X X 2
Falcone East X X X X 2
Falcone North X X X X 2
Falcone West X X X X 2
Fenway Apts. X X X N/A 2
Forest Hall X X X X 2
Kresge Hall X X X X 2
Maple Hall X X X X 2
Miller Hall X X X X 2
North Campus A X X X X 2
North Campus B X X X X 2
North Campus C X X X X 2
North Campus D X X X X 2
Oak Hall X X X X 2
Orchard North X X X X 2
Orchard South X X X X 2
Rhodes Hall X X X X 2
Slade Hall X X X X 2
Spruce Hall X X X X 2
Stratton House X X X N/A 2
N/A =
No Attic
36 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 37
22
18
17
16
15
14
13
12
9
3
20
19
11
10
8
7
6
5
4
2
1
Evacuation Meeting Areas
NO. Evacuating Building Evacuation Meeting Area
1 Library West porch of Adamian Academic Center
1 Morison Hall West porch of Adamian Academic Center
2 Adamian Academic East porch of Baker Library
Center
3 Boylston Apartments North entrance to Student Center
3 Rhodes Hall North entrance to Student Center
4 Jennison Hall LaCava Quad leading up to Library
4 LaCava Center LaCava Quad leading up to Library
4 Rauch Building LaCava Quad leading up to Library
5 Smith Technology West porch of Lindsay
Center
6 Falcone Apartments Greenspace
7 Miller Hall East side of north parking lot
by parking deck
8 Collins Hall BBQ area at north side of Collins
9 Forest Hall Pedestrian walk intersection at
Rhodes/Student Center/Kresge
NO. Evacuating Building Evacuation Meeting Area
9 Kresge Hall Pedestrian walk intersection at
Rhodes/Student Center/Kresge
9 Student Center Pedestrian walk intersection at
Rhodes/Student Center/Kresge
10 Slade Hall Lawn /bus stop at Circle Road
by the Tree Dorms
10 Tree Dormitories Lawn /bus stop at Circle Road
by the Tree Dorms
11 Lindsay Hall South side of rear parking lot
12 University Police Side of CP parking lot across
from dispatch
13 Orchard North Lower Campus Greenspace
13 Orchard South Lower Campus Greenspace
14 Cape and Lawn by entrance to Copley Circle
Castle Houses
15 Copley North North entrance of Fenway Hall
NO. Evacuating Building Evacuation Meeting Area
15 Copley South North entrance of Fenway Hall
16 Fenway Hall Main entrance to Copley South
17 Lewis Hall BBQ area at east side of
Orchard South
18 Dana Athletic Center South side of parking lot
19 Stratton House South side of parking lot
20 Harrington House West parking area
21 North Campus A Center BBQ area of North Campus
21 North Campus B Center BBQ area of North Campus
21 North Campus C Center BBQ area of North Campus
21 North Campus D Center BBQ area of North Campus
22 Dove Cote South entrance to Orchard South
22 Maintenance Building South entrance to Orchard South
21
38 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 39
Title IX and Gender-Based Harassment
and Discrimination Policy
THE MISSION OF BENTLEY UNIVERSITY: To educate creative, ethical, and
socially responsible organizational leaders by creating and disseminating
impactful knowledge within and across the business and the arts and
sciences.
THE MISSION AND PURPOSE OF THIS POLICY: To eliminate all barriers
on Bentley University’s campus that are rooted in forms of discrimination,
harassment, and retaliation on the basis of an individual’s sex, gender,
sexual orientation, gender identity, and/or gender expression. To ensure
compliance with federal and state civil rights laws and regulations, and to
afrm its commitment to promoting the goals of fairness and equity in all
aspects of the educational program or activity
QUESTIONS REGARDING THIS POLICY: Please forward any questions,
complaints, or notice of alleged policy violations, or regarding this policy
and procedures, to those responsible for Bentley’s Title IX and Gender-Based
Harassment and Discrimination Policy compliance below:
Liz Humphries
Title IX Coordinator
Associate Director, Student Conduct
Student Center 320
ehumphries@bentley.edu
781-891-2225
Justin Woodard
Deputy Title IX Coordinator for Student Support
Associate Director, Residential Center
Student Center 320
jwoodard@bentley.edu
781-891-2319
Kelly Kelleher
Deputy Title IX Coordinator for Faculty/Staff Support
Business Partner, Human Resources
Rauch 201
781-891-2676
Courtney Finn
Deputy Title IX Coordinator/Senior Women’s Administrator
Associate Director, Athletics
Dana Center
781-891-2368
I. Policy Statement and Overview
Bentley University will always respond to complaints, reports, allegations,
and information about harassment, sex-and gender-based discrimination,
and retaliation regardless of how the information was brought to the
University's attention. The University’s response is designed to stop the
prohibited conduct, prevent its recurrence, and address any lingering impact
that it had on individuals, members of the campus community, and all
University-related programs or activities.
Bentley University is rmly committed to establishing an environment free
of harassment and discrimination on the basis of sex or gender in any of
its education or employment programs and activities. This policy prohibits
sexual and gender-based harassment, sexual assault (non-consensual
sexual touching, forcible or not), stalking, domestic violence, and sexual
exploitation, stalking, and retaliation (collectively referred to in this policy
as prohibited conduct). These forms of prohibited conduct are harmful to
the well-being of our campus community and its members, the learning
and working environment, and collegial relationships among our students,
faculty, and staff.
All violations of prohibited conduct under this policy will result in discipline,
including potential separation from the University. Some forms of prohibited
conduct may also violate state and federal laws, and criminal prosecution
may occur independently of any disciplinary action imposed by the
University.
This policy also sets forth the procedures that will be used to respond and
investigate reports of prohibited conduct.
Bentley University complies with Title IX of the Education Amendments
of 1972 (Title IX), which prohibits discrimination on the basis of sex in the
University's programs and activities; the Jeanne Clery Disclosure of Campus
Security Policy and Campus Crime Statistics Act (Clery Act), as amended
by the Violence Against Women Reauthorization Act of 2013 (VAWA) as
amended; Title VII of the Civil Rights Act of 1964; and its stated counterpart,
M.G.L. c.151B; Section 504 of the Rehabilitation Act and the Americans with
Disabilities Act, and other applicable law.
40 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 41
Bentley also reafrms the rights impacted parties to decide whether they
wish to be involved in any of the University’s processes to address sexual
harassment and sex-and gender-based harassment, discrimination, and
retaliation. Bentley is also strongly committed to supporting impacted
parties through the numerous support service available. All students
and employees have access to condential resources that they may use
for support and guidance regardless of whether they make a report to the
University or participate in a University investigation and adjudication
process, please refer to Appendix A. The University encourages those who
wish to receive condential support services regarding sex-and gender-based
discrimination and harassment under these policies to seek assistance from
staff in the Counseling Center, the Health Center, the Boston Area Rape Crisis
Center, REACH Beyond Domestic Violence, and/or seek medical attention.
Responsible employees of the University are expected to report allegations of
sexual harassment and other forms of sex- and gender-based discrimination
that they observe or learn about to the Title IX Coordinator. Employees
whose positions legally require condentiality (i.e., licensed mental health
counselors and health professionals) are not responsible employees. To
review the full list of designations of employees at Bentley University,
please refer to Appendix E. If you have a question regarding reporting
responsibilities, please contact the Title IX Coordinator.
All employees of Bentley University are strongly encouraged to offer
information on how to report such incidents to students and colleagues, as
well as report this conduct directly to the Title IX Coordinator. Responsible
employees who fail to report allegations of sexual harassment and other
forms of sexual misconduct that they observe or learn about may be subject
to disciplinary action. Bentley University is mandated to respond promptly
and appropriately to any allegations of sexual harassment or other forms
of gender-based discrimination and retaliation. Under these policies, the
University will consider the effects of off-campus conduct for faculty, staff,
students, visitors, and community members when evaluating whether a
hostile environment was created on campus.
Any person responsible for or involved in retaliation will be subject to
disciplinary action up to and including expulsion or termination.
Retaliation against anyone who reports an incident of harassment, or
discrimination as dened in this policy, brings forward a complaint or
participates in an investigation and adjudication process under this policy
is prohibited. Retaliation is also prohibited against those who, in good faith
and reasonable manner, oppose an act or policy believed to constitute sex-
or gender-based discrimination and harassment. It is the responsibility of
Bentley University’s Title IX Coordinator to ensure that inquiries into reports
of misconduct described above are made, as well as formal investigations
and resolutions consistent with applicable adjudication procedures that are
described in this policy.
Additionally, Bentley seeks to ensure that our campus and culture are
inclusive for all students, and, as such, has committed to engaging in several
preventative and proactive educational programs and initiatives. For a list of
some of the programs Bentley offers, please see Section XVII of this document.
Bentley reserves the right to amend this and other policies immediately to
ensure compliance with federal and state rules, regulations, and laws.
II. Bentley’s Title IX Coordinator and Title IX Staff
The Title IX Coordinator for Bentley University is responsible for providing
leadership regarding Title IX and the Gender-Based Harassment and
Discrimination Policy. The Title IX Coordinator has the primary responsibility
for coordinating Bentley’s efforts related to the intake, investigation, resolution,
and implementation of supportive measures to stop, remediate, and prevent
discrimination, harassment, and retaliation prohibited under this policy.
The Title IX Coordinator will also ensure that ongoing training and education
regarding sex/gender-based harassment, discrimination, and retaliation
take place, as well as compliance-related reporting. Additionally, the Title IX
Coordinator will be responsible for:
■ Tracking and monitoring incidents, including sex-based discrimination,
harassment, retaliation, and other sexual misconduct outlined in this
policy;
■ Ensuring that the University responds effectively to each report; and
■ Provides appropriate supportive measures to parties involved with or
without the ling of a formal complaint
After an alleged violation of this policy is reported, the Title IX Coordinator
will ensure that the appropriate measures are taken, including providing
supportive measures, obtaining an external investigator, assigning advisors,
and which resolution process will apply based on the allegations raised.
However, the Title IX coordinator will not participate in the investigation,
the resolution process, or decision making regarding the investigation report
(see Appendices C and D for more information on investigation procedures
and protocols).
Bentley University also has three Deputy Title IX Coordinators. These
42 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 43
individuals can offer further information to those who may have questions
about these policies, and formal reports can be submitted to them. The
Deputy Title IX Coordinators will also keep individuals involved in the formal
investigations process and provide updates regarding its progress. Similar to
the Title IX Coordinator, the Deputy Title IX Coordinators will not participate
in the investigation, the hearing panel, or in the deliberations regarding the
investigation report. The Title IX Coordinator and Deputy Title IX Coordinators
will act with independence and authority free from bias and conicts of interest.
The Title IX Coordinator and Deputy Title IX Coordinators are knowledgeable
about and will provide information on all options for report resolution. Both the
Title IX Coordinator and the Deputy Title IX Coordinators can assist in providing
supportive measures to remedy the impact of an incident.
In addition to the Title IX Team members listed above, Bentley has determined
administrators as Ofcials with Authority to address and correct harassment,
discrimination, and retaliation. These Ofcials with Authority listed below may
also accept notice or complaints on behalf of Bentley University.
John Piga
Associate Dean of Student Affairs
Student Center 320
jpiga@Bentley.edu
781-891-2148
George Cangiano
Vice President & Chief Human Resources Ofcer
Rauch 318
gcangiano@bentley.edu
781-891-2380
III. Scope of this Policy
The federal mandates established by Title IX and the Clery Act reafrm that
students, staff, faculty, and third parties (i.e., non-members of the University
community, such as vendors, alumni/ae, and visitors) have the right to be
free from discrimination based on their gender, sex, sexual orientation, and
gender appearance/expression.
Third parties are both protected by and subject to this policy. A third party
may report potential policy violations committed by a member of the
University community, and the University will take appropriate steps to
investigate and respond to the conduct consistent with the authority granted
by the University’s jurisdiction, if any, over the respondent. A third party
who is accused of violating University policy may be permanently barred
from the University or subject to other restrictions for failing to comply with
this policy and may not be granted the full rights and processes afforded to
Bentley community members through the provisions of this policy.
All procedures regarding incidents involving students can be found in
Appendix C of this policy, while all procedures for incidents involving
employees are found in Appendix D of this policy
IV. Jurisdiction of this Policy
This policy applies to the education program and activities of the University,
to any behaviors or conduct that takes place on the campus or property
owned or controlled by the University, at University-sponsored events, or in
buildings owned or controlled by student organizations that are recognized
by the University.
This policy can also apply to the effects of off-campus misconduct. Thus, the
policy applies to any behaviors involving community members both on and
off-campus.
The University may also extend jurisdiction to off-campus and/or to online
conduct when the Title IX Coordinator determines that the behavior affects a
substantial University interest.
Regardless of where the conduct occurred, Bentley will address any
complaints and determine whether the conduct occurred in the context
of its employment or educational program or activity and/or has
continuing effects on campus or in an off-campus sponsored program
or activity. The alleged violations and/or the location (jurisdiction) of
where the alleged behavior took place, will determine which adjudication
process is applied: the Title IX Adjudication Process or the Gender-Based
Harassment & Discrimination Adjudication (GBHD) Process. Examples of
off-campus coverage of this policy include incidents that occur on faculty-
led study abroad trips, the Commencement Week trip for graduating
seniors, internship programs/sites, service-learning sites, and off-campus
residences of students.
The Respondent must be a member of the University community in order
for its policies to apply. However, if the Respondent is unknown or is not a
member of the University’s community, the Title IX Coordinator will assist
the Complainant in identifying appropriate campus and local resources and
support options and/or, when criminal conduct is alleged, in contacting
local or campus law enforcement if the individual would like to le a police
report.
44 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 45
Furthermore, even when the Respondent is not a member of the Bentley
community (where the University does not have disciplinary authority over
the Respondent), the Title IX Coordinator will still take reasonably available
steps to support a Complainant through supportive measures, remedies,
and resources.
When the Respondent is enrolled in or employed by another institution,
the Title IX Coordinator can assist the Complainant in liaising with the
appropriate individual at that institution, as it may be possible to allege
violations through that institution’s policies.
Similarly, the Title IX Coordinator may be able to assist a student or
employee Complainant who experiences discrimination in an externship,
study abroad program, or other environments external to the University
(whereas the facilitating or host organization may give recourse to the
Complainant through its policies and procedures of sexual harassment, non-
discrimination, and retaliation).
The University will not release copies of evidence, including any reports
related to the incident, outside of the University, except for an instance
in which the University receives a legally issued subpoena. The Title
IX Coordinator and Deputy Coordinators will share reports with any
involved party verbally over a video teleconference or in person, if
available, in the Student Center suite 320. Parties who read or view reports
or evidence in person will be prohibited from copying, taking pictures, or
otherwise disseminating the content. This is done intentionally to ensure
condentiality and privacy.
V. Coordination with Other Bentley University Policies
This policy addresses sexual and gender-based harassment, sexual assault
(non-consensual sexual touching, forcible or not), stalking, domestic violence,
and sexual exploitation, stalking, and retaliation (collectively referred to in
this policy as prohibited conduct and dened in more detail below).
Other forms of sex discrimination (not based on harassment or violence),
and discrimination and harassment based on race, color, nationality or
ethnic origin, sex, age, or disability are governed by the University’s Non-
Discrimination Policy
In addition, the conduct of students, employees, and faculty is governed by the
following policies:
1. Student Code of Conduct
■ Applies to all other forms of student misconduct (e.g., alcohol, drug
use, threats or physical abuse, possession of rearms, etc.)
■ Overseen by the Student Conduct system.
2. Employment Policies and Practices
■ Set the standards of personal conduct for employees
■ Include the staff disciplinary and adjudication policies
■ Overseen by Vice President and Chief Human Resources Ofcer
3. Faculty and Staff Handbook
■ Sets the standards of personal conduct for faculty members
■ Includes the statement of academic freedom (See Also Academic
Freedom and Freedom of Speech, below)
■ Consists of the University’s adjudicatory policy
■ Overseen by Vice President and Chief Human Resources Ofcer
4. University Policy on Consensual Relationships
■ Prohibits romantic and/or sexual relationships between employees
and students (undergraduate, graduate or doctoral), and employees
and any individual whom that person supervises or evaluates in any
way
Where conduct involves the potential violation of both this policy and
another University policy, the University may choose to investigate other
potential misconduct under the procedures outlined in this policy, instead
of the procedures ordinarily used to address potential violations of such
other University policies, provided that it does not unduly delay a prompt or
equitable resolution of the report.
VI. Academic Freedom and Harassment
Bentley University is committed to principles of free speech and upholding
the tradition of academic freedom. This policy is not intended to restrict
teaching methods or freedom of expression, nor will it be permitted to do
so. Harassment or discrimination prohibited by this policy is not a proper
exercise of academic freedom.
VII. Accommodations for Students with Disabilities:
Bentley is committed to compliance with the Americans With Disabilities
Act of 1990 (ADA), as amended, and Section 504 of the Rehabilitation
Act of 1973, which prohibit discrimination against qualied persons
with disabilities, as well as other federal and state laws and regulations
pertaining to individuals with disabilities.
46 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 47
By federal law, a person with a disability is any person who: 1) has a physical
or mental impairment; 2) has a record of such impairment; or 3) is regarded
as having such an impairment, which substantially limits one or more major
life activities such as self-care, walking, seeing, hearing, speaking, breathing,
or learning. A student requesting an accommodation regarding a Title IX
investigation/adjudication process must follow the appropriate procedure
for requesting an accommodation through the Ofce of Disability Services
(located in Jennison Hall). Additionally, the Ofce of Disability Services can
provide students with a comprehensive list of off-campus resources.
The Ofce of Disability Services will make a determination regarding the
request and notify the appropriate parties. Reasonable accommodations
depend upon the nature and degree of severity of the documented disability.
While the ADA requires that priority consideration be given to the specic
methods requested by the student, it does not imply that a particular
accommodation must be granted if it is deemed not reasonable and other
suitable techniques are available. For more information regarding options
for assistance, regarding both immediate and ongoing concerns, please see
Appendices A and B.
VIII. Resources for Information and Assistance
Bentley University offers various resources for students, staff, and faculty
seeking information or support under Title IX and Gender-Based Discrimination
and Harassment Policy. Bentley also acknowledges that each person experiences
and responds in differing ways and there are a variety of formal and informal
options for support. Please review the information regarding your options for
support, assistance, and reporting so that you can make an informed decision
based on personal needs. Your needs may change over time, so please also know
that you may choose to utilize different forms of response at different times.
Any member of the Bentley community (including visitors) is welcome to
contact the Title IX Coordinator for information regarding these policies or the
procedures outlined within it. The resources highlighted in Appendix A and B
also provide information, assistance, and support to those who seek it.
IX. Condentiality, Privacy, and Reporting Responsibilities of
Bentley Employees
Issues of privacy and condentiality play important roles in this policy and
may affect individuals differently. While they are closely related, the concepts
of privacy and condentiality are distinct terms that are dened below.
A. Condentiality
Condentiality refers to the protection of information disclosed to individuals such
as licensed professional mental health counselors, licensed medical professionals,
and ordained clergy. When an individual shares information with a condential
resource (on campus or in the community), that is a condential communication
that will not be reported to the Title IX Coordinator under this policy.
At Bentley, complete condentiality can only be guaranteed when a concern is
shared with clinicians in the Health Center, the Counseling Center, Spiritual
Life Staff, Staff within the Center for Wellness and Health Promotion, and the
Ombudsperson, and when the concern does not involve a continuing threat of
serious harm to self or others.
When an individual shares information with a condential resource, the details
of that communication will not be reported, and the identity of the reporting
party will be protected by the Condential resource. If a disclosure is made to a
Condential Employee, that employee will only share non-identiable information
with the Title IX Coordinator or Deputy Coordinators. (i.e. 1 count of Sexual Assault,
on-campus, residence hall, month of September). Condential Resources may be
deemed as condential through their professional licensure (i.e. physicians) or
through this policy. Professional Staff within the Center for Wellness and Health
Promotion and the Ombudsperson are deemed as Condential Employees under
this policy.
A list of Condential Resources on and off-campus is available in Appendix E.
Condential Resources submit non-personally identiable information about Clery-
reportable crimes to the Bentley University Police Department for purposes of
anonymous statistical reporting under the Clery Act. (i.e. 1 count of Sexual Assault,
on-campus, residence hall, month of September).
B. Privacy
Privacy refers to the discretion that will be exercised by the University
in the course of any investigation or other processes under this policy.
Bentley understands that breaches of privacy compromise the ability of
the University to investigate and resolve claims of prohibited harassment,
discrimination, and retaliation. The Title IX Coordinators will attempt to
protect the privacy of all reports and proceedings to the extent reasonably
possible. Information related to a report of prohibited conduct will be shared
in the most limited manner possible with University employees who need
to know in order to assist in the assessment, investigation, and resolution
of the report and related issues. Additionally, in order to comply with its
obligations regarding campus safety and Title IX, University employees
receive training in how to safeguard private information. The University
will make reasonable efforts to investigate and address reports of prohibited
48 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 49
conduct under this policy, and information may be disclosed to participants
in an investigation as necessary to facilitate the thoroughness and integrity
of the investigation. In all such proceedings, the University will take into
consideration the privacy of the parties to the extent reasonably possible.
The privacy of student education records is governed by the Family
Educational Privacy Act (FERPA).
C. Disclosures and Reporting Responsibilities of Bentley Employees
All involved parties have many options, including seeking counseling or
assistance from a Condential Resource, making a report under this policy, and/
or making a report to law enforcement. The University recognizes that deciding
among these options can be difcult and is an intensely personal decision.
Individuals are encouraged to seek assistance and to explore all potential
reporting and support options.
Please note that faculty and staff members on campus have different roles and
responsibilities for reporting information should a student disclose any prohibit
conduct under this policy.
It is important to understand the different responsibilities of Bentley’s
employees. Every employee is designated as either a Condential Employee, a
Responsible Employee, and all Other Employees.
CONFIDENTIAL EMPLOYEES: This is an employee who may talk to an
individual in condence, and generally only report to the University that an
incident occurred without revealing any personally identifying information.
Disclosures to these employees (e.g., physicians, nurses, professional counselors,
clergy) will not trigger an investigation into an incident against the individual’s
wishes. If a disclosure is made to a Condential Resource, that employee
will only share non-identiable information with the Title IX Coordinator or
Deputy Coordinators. (i.e. 1 count of Sexual Assault, on-campus, residence hall,
month of September).Condential Resources may be deemed as condential
through their professional licensure (i.e. physicians) or through this policy.
Professional Staff within the Center for Wellness and Health Promotion and the
Ombudsperson are deemed as Condential Employees under this policy.
RESPONSIBLE EMPLOYEES: Include faculty and staff, who are expected to
call the Title IX Coordinator when an incident of sexual violence, misconduct,
gender-based harassment, discrimination and/or retaliation is reported to
them, especially if there is cause for fear of a person’s safety. The disclosure
includes the identities of both the Complainant and Respondent (if known)
to the Title IX Coordinator. A report to responsible employees constitutes
a report to Bentley and obligates the University to respond to the incident
and take appropriate steps to address the situation. When a responsible
employee receives a disclosure and noties the Title IX Coordinator, the
Title IX Coordinator or Deputy Coordinators reach out to the Complainant to
provide immediate resources and information, as well as an offer to meet to
discuss options further. A community member will never be forced to speak
with the Title IX Coordinator or Deputy Coordinators until, and if, they would
like to.
ALL OTHER EMPLOYEE: Include faculty members and other Bentley staff
employees who do not fall under the categories of Condential Employees
or Responsible Employees. While these employees do not have any
expectation to keep shared concerns condential and are not required
to report those concerns, the University encourages them to assist an
individual who shares concerns. Individuals may seek advice from any
other these employees on campus after an incident occurs. If you are
unsure of someone’s duties and ability to maintain your privacy, ask them
before you talk with them.
This policy is intended to make members of the community aware of
the various reporting and condential disclosure options available to
them. Ideally, this information will inform individuals so they can make
deliberate choices about where to turn should they experience sexual
misconduct, gender-based harassment, discrimination, and/or retaliation.
Bentley encourages impacted parties to talk to someone identied in one or
more of these groups. For more information on which employees serve in
each of these capacities, please see Appendix E..
X. Supportive Measures
One way in which Bentley will support those who bring forward claims of
sexual misconduct, sex-or gender-based discrimination, harassment, and
retaliation is to offer individualized supportive measures, without any
fee or charge. Supportive measures are non-disciplinary, non-punitive
personalized services offered to parties. The goal of supportive measures is
to provide support to remedy the impact of the alleged misconduct, preserve
equal access to education, and protect safety. Supportive measures are
available with or without the ling of a formal complaint.
Examples of supportive measures include:
■ Implement contact limitations (“University No Contact Orders”) to all
parties involved
■ Changes in housing assignment or room combination
■ Assistance from support staff
■ Academic support services
50 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 51
■ Help in rescheduling exams; extensions of a deadline; and other course-
or program-related adjustments
■ Limiting access to University facilities and activities pending resolution
of the matter
■ Change in class schedule, withdrawals, or leave of absence
■ Change in work schedule or job assignment
■ Arrangements for counseling, medical, and/or other health services
■ Safety planning
■ Providing campus security escorts
■ Provide transportation accommodations
■ Increased security and monitoring of certain areas of the campus
■ Guided conversations to confront behavior
■ Action planning to resolve a conict in the future
These are just some examples of the supportive measures that the University may
take to support individuals involved in an incident of sexual misconduct, sex-or
gender-based discrimination, harassment, and retaliation. As each individual
will have their own needs and requests, the University is committed to tailoring
supportive measures to the specics of each incident, in a fair and equitable
manner (without unreasonably burdening the other party). Individuals seeking
to access supportive measures can contact the Title IX Coordinator or the Deputy
Title IX Coordinators. The decision to impose supportive measures is made at the
discretion of the Title IX Coordinator. The University will also enforce any orders
that are issued by the Courts of the Commonwealth of Massachusetts.
XI. Emergency Removal
Bentley can act to remove a Respondent entirely or partially from its education
program or activity on an emergency basis after an individualized safety and risk
analysis, it is determined that such a removal is justied because the Respondent
poses an immediate threat to the physical health or safety of any student or
other individuals arising from the report or prohibited conduct under this policy.
The risk analysis is performed by Senior Level Administrators, including the Title
IX Coordinator, the Bentley University Police Department, and Student Affairs
Staff Members using its standard objective violence risk assessment procedures.
Under these circumstances, the Respondent will be notied in writing of the
emergency removal from the University’s education program or activity, and
the Respondent will have an opportunity to immediately challenge the decision
following the emergency removal.
XII. Dening and Recognizing Prohibited Conduct
Conduct that is prohibited and encompassed by the Title IX policy includes
sexual harassment, as an umbrella category, which includes the offense
of sexual harassment, sexual assault, dating violence, domestic violence,
and stalking. It is a violation of this policy to either commit these acts or
attempt to commit them. These acts are also a violation of federal and state
law (including Title IX, the Clery Act, and the Violence Against Women Act).
These acts are prohibited in any sex or gender conguration (i.e., between
the same or differing genders), regardless of sex and gender identity.
Individuals found responsible for violating these policies will face sanctions
that are commensurate with the severity of the policy violation, ranging
from probation through expulsion.
A. Definition of the Prohibited Conduct Under the Title IX Policy:
1. SEXUAL HARASSMENT: Bentley University adheres to the following
denition of sexual harassment as an umbrella category, which includes the
offenses of sexual harassment, sexual assault, domestic violence, dating
violence, and stalking.
Generally, this umbrella category prohibits unwanted conduct of a sexual
nature that may take the form of sexual advances, inappropriate sexual
or suggestive comments, inquiry, sounds or jokes; unsolicited touching or
fondling; unwanted intercourse, or assault.
Sexual Harassment is dened as follows:
i. Unwelcome requests for sexual favors; and/or
ii. Other behavior of a sexual nature where:
a.Submission to such conduct is made either explicitly or implicitly as
a term or condition of an individual's employment or participation in
a university-sponsored educational program or activity. Submission
to or rejection of such conduct by an individual is used as the basis
for academic or employment decisions affecting that individual (often
referred to as quid pro quo harassment); or
b.Such conduct has the purpose or effect of unreasonably interfering
with an individual's academic or work performance, as well as creating
an intimidating or offensive educational, social, living, or working
environment.
iii. Harassing conduct that is sufciently severe, pervasive, and objectively
offensive(often referred to the as hostile environment). Such conduct denies,
limits, or interferes with the ability to participate in, or benet from:
a. Educational programs, services, opportunities, or activities; or
b. Employment access, benets, or opportunities.
52 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 53
2. SEXUAL ASSAULT is a form of sexual misconduct that is a violation of
University policy as well as federal and state statutes. The Commonwealth
of Massachusetts denes sexual assault as "any sexual activity that is forced,
coerced, or unwanted" and refers to the crimes of rape and indecent assault
and battery. Bentley University adheres to the following denitions of rape
and indecent assault and battery:
i. Rape includes penetration (oral, anal, or vaginal) no matter how slight,
of any orice with a body part or any object without effective consent.
ii. Indecent Assault and Battery includes non-consensual sexual contact
without penetration.
iii. Incest sexual activity between family members or close relatives.
iv. Statutory rape, which in Massachusetts is when a person has sexual
intercourse with an individual under age 16.
The severity of the violation is the same whether the Respondent is a
stranger or known to the Complainant. All students, faculty, and staff should
be aware that the University is prepared to respond to any incidents of
sexual assault. Individuals found responsible for violating this policy will
face sanctions that are commensurate with the severity of the violation,
including University expulsion.
3. RELATIONSHIP VIOLENCE: At Bentley, relationship violence encompasses
dating violence and domestic violence and can involve current or former
intimate partners, spouses, social or dating relationships.
Dating Violence and Domestic Violence: is any act of violence or pattern of
abusive behavior in a relationship. The acts of violence or abuse can be but
are not limited to actual or threatened physical, sexual, verbal, emotional,
nancial, or digital. It is unwanted and causes physical or emotional harm.
Relationship violence occurs in both same-sex and opposite-sex relationships.
The determination of the existence of a relationship is based on the following
factors: the length of the relationship, the type of relationship, and the
frequency of interaction between the persons involved in the relationship. All
students, faculty, and staff should be aware that the University is prepared
to respond to any incidents of dating violence and domestic violence.
Individuals found responsible for violating this policy will face sanctions that
are commensurate with the severity of the violation, including University
expulsion.
Examples of relationship violence include, but are not limited to:
■ Physical abuse: hitting, slapping, shoving, grabbing, pinching, biting,
hair pulling, or throwing objects at a person.
■ Sexual abuse: attacks on sexual parts of the body, forcing sex after
physical violence, treating one in a sexually demeaning manner,
coercing or attempting to coerce any sexual contact or behavior without
consent, or marital rape.
■ Psychological or emotional abuse: a pattern of behavior undermining
a person’s sense of self-worth or self-esteem, constant criticism,
possessiveness, damaging possessions, threats, intimidation,
diminishing a person’s abilities, name-calling, public humiliation, and
damaging a person’s relationship with their friends or family.
■ Financial abuse: Taking money from or prohibiting access to bank
accounts.
■ Digital abuse: Controlling social media accounts, or harassment
through social media or other forms of technology.
4. STALKING: is a course of conduct directed at a specic person that is
unwelcome, repeated, and would cause a reasonable person to fear for their
safety, fear for the safety of others, or suffer emotional distress. Stalking can
occur between strangers, individuals who know each other, or individuals
who are or were previously in a relationship. Stalking behaviors may include
unwanted following or watching, unwelcome gifts, or communications in
person, in writing, or through the use of technology. It also includes accessing
personal information to monitor a person’s activity. Any stalking behavior
can be done directly, indirectly, or through a third-party. For purposes of this
denition, a reasonable person means a reasonable person under similar
circumstances and with similar identities to the Complainant. Individuals
found responsible for violating this policy will face sanctions that are
commensurate with the severity of the violation, including University
expulsion.
B. Other Prohibited Conduct – Gender-Based Harassment and
Discrimination (GBHD)
In addition to the forms of sexual harassment described above, which fall
within the coverage of Title IX, Bentley additionally prohibits the following
offenses as forms of discrimination outside of Title IX when the act is based
upon the Complainant ’s actual or perceived membership in a protected class.
1. SEXUAL EXPLOITATION: Sexual exploitation occurs when a person takes
non-consensual, unjust, or abusive sexual advantage of another for their own
advantage or benet, or for the benet or advantage of anyone other than the one
being exploited. This behavior may not fall within the denition of non-consensual
sexual contact/activity or sexual harassment, but it is still a violation of policy.
There are many degrees and types of sexual exploitation, including, but not
54 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 55
limited to:
i. Photographing or Video/Audio Taping Sexual Contact or Activity:
Photographing or taping someone (via audio or video) involved in sexual
activity, or in a state of undress without their consent or knowledge
constitutes prohibited sexual exploitation. Even if a person consented
to the sexual activity or intercourse, photographing or taping someone
without their knowledge goes beyond the boundaries of that consent.
ii. Disseminating Photographs or Video/Audio Tapes of Sexual Contact or Activity:
The dissemination of photographs or video/audio of someone involved in
sexual activity, or in a state of undress without their knowledge or consent
constitutes a separate and additional act prohibited by this policy.
iii. Voyeurism: Voyeurism is the act of observing, spying on, or listening
to a person involved in sexual contact/activity, or in a state of undress
without their knowledge or consent.
iv. Inducing Intoxication/Incapacitation for the Purpose of Sexual Activity:
Offering drugs, alcohol, or other substances to a person with or without
their knowledge with the intent to impair their ability to withhold
consent or their ability to knowingly consent to sexual activity is
a violation of this policy. This type of conduct constitutes sexual
exploitation, regardless of whether any sexual activity takes place.
2. HARASSMENT BASED ON SEXUAL ORIENTATION, GENDER, OR GENDER
IDENTITY: Harassment based on sexual orientation, gender, or gender
identity is dened as derogatory comments, actions, or conduct that may
include acts of verbal, nonverbal, cyber, or physical aggression, intimidation,
or hostility, even if those acts do not involve conduct of a sexual nature.
Such conduct is directed toward an individual by virtue of their actual or
presumed sexual orientation, gender, or gender identity and:
i. Humiliates or intimidates an individual;
ii. Impedes academic or work performance; and/or
iii. Interferes with university life.
3. ONLINE MISCONDUCT: The University’s harassment policies are written
and interpreted broadly to include online and virtual conduct that have
an effect on its education program and activities. Any behavior that is
prohibited by the policy is also prohibited in cyber-forms through the use of
technology, networks, or equipment.
While the University may not control websites, social media, and other
venues in which harassing communications are made, however, when
such communications are reported, it will respond in a variety of means to
address and mitigate the effects.
Bentley encourages members of the community to be good digital citizens and to
refrain from online misconduct. Examples of online misconduct include but not
limited to: feeding anonymous gossip sites, sharing inappropriate content via web/
video conferencing, text messages, emails, chats, instant messaging, screensavers,
blog, or other social media sites, unwelcome sexting, revenge porn, breaches of
privacy, or otherwise using the ease of transmission and/or anonymity of the
Internet or other technology to harm another member of the campus community.
4. COMPLICITY: Complicity is any act taken with the purpose of aiding,
facilitating, promoting, or encouraging the commission of an act of
prohibited conduct by another person.
5. RETALIATION: Retaliation occurs when an adverse action is taken against
an individual for raising concerns about conduct which is prohibited by
law or policy. All members of the Bentley community have the right to
raise concerns or le a complaint through the student conduct system
without fear of retaliation. Additionally, it is both unlawful and a violation
of University policy to retaliate against an individual for ling a report of
sexual misconduct, gender-based discrimination, or harassment. Retaliation
is also prohibited against anyone who participates, assisted, or refused to
participate in an investigation or adjudication of sexual misconduct, gender-
based discrimination, and harassment. Acts of alleged retaliation should
be reported immediately to the Title IX Coordinator and will be promptly
investigated. Bentley is prepared to take appropriate steps to protect
individuals who fear that they may be subjected to retaliation. Examples of
retaliation can include hostility, intimidation, threats, coercion, exclusion,
or discrimination directly or indirectly. Individuals found responsible for
violating this policy will face sanctions that are commensurate with the
severity of the violation, including University expulsion.
Retaliation, or the perception, of, can be committed by any person who
retaliates against:
i. anyone ling a report of under this Policy or a Formal Complaint,
ii. the parties or any other participants (including any witnesses or any
University employee) in the Adjudication Process relating to a Formal
Complaint,
iii. any person who refuses to participate in the Adjudication Process, or
iv. any person who under this Policy opposed any unlawful practice is
subject to disciplinary action up to and including dismissal or separation
56 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 57
from the University. If any participant in the Adjudication Process
believes they have been subject to Retaliation (as dened in this Policy),
they should immediately report the alleged retaliatory conduct to the
Title IX Coordinator.
XIII. Denition of Consent
A. Bentley’s University’s denition of consent applies to all of the acts listed
above as prohibited conduct under this policy. Bentley University adheres to
the following denition of consent:
Consent is a clear and voluntary agreement to engage in specic acts of
sexual contact or activity, communicated through mutually understandable
words or actions. Consent is always freely informed and actively given.
Consent is an afrmative process. It is the responsibility of the person who
wants to engage in sexual activity to make sure that they have received
consent. If an individual initiating sexual activity is not sure if they have
received consent, they have an obligation to seek additional clarication,
as consent cannot be based on assumption. The existence of a dating
relationship does not imply consent, and even once consent has been given,
it can be withdrawn at any time. If consent is withdrawn, that sexual activity
should cease immediately.
Consent can never be assumed or implied. The absence of “No” or silence does
not mean that consent has been given. Additionally, consent to one form of
sexual activity does not imply consent to other forms of sexual activity.
Consent is not present and may never be obtained:
i. Through the use of coercion, manipulation, intimidation, or force;
ii. From an individual who is incapacitated; or
iii. From an individual who is under the legal age of consent (16 in the
state of Massachusetts).
iv. Denitions of coercion, force, and incapacitation are included below:
B. COERCION is unreasonable pressure for sexual activity. Coercion
can include the use of verbal or physical conduct such as manipulation,
intimidation, isolation, force, or threats. Coercion includes continued
pressure after an individual has made it clear that they do not want to
engage in the behavior. Coercive behavior differs from seductive behavior
based on the type of pressure someone uses to get consent from another.
When someone makes clear to you 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.
C. FORCE is not only limited to physical violence but also includes threats,
intimidation, abuse of power, coercion, duress, or any combination of
these behaviors to overcome an individual’s freedom to choose whether
to engage in sexual activity. Sexual activity that is forced is, by denition,
non-consensual. Silence or the absence of resistance alone is not consent.
Consent is not demonstrated by the absence of resistance. While resistance
is not required or necessary, it is a clear demonstration of non-consent.
D. INCAPACITATION consent is not present when an individual is
incapacitated. An Incapacitated individual is someone who cannot make
rational, reasonable decisions because they lack the capacity to understand
the “who, what, when, where, why, or how” of sexual interaction. This
includes a person whose incapacity results from mental disability, sleep,
involuntary physical restraint, unconsciousness, or use of alcohol or other
drugs. Incapacitation is a state beyond drunkenness or intoxication. A person
is not necessarily incapacitated merely as a result of drinking or using drugs.
The impact of alcohol and other drugs varies from person to person, and if
there is any doubt as to the level or extent of the other person’s intoxication
or impairment, the prudent course of action is to forgo or cease any sexual
contact or activity.
a. In evaluating consent in cases of alleged incapacitation, the University
asks two questions: (1) Did the person initiating sexual activity know that the
other party was incapacitated? and if not, (2) Should a sober, reasonable person
in the same situation have known that the other party was incapacitated? If the
answer to either of these questions is “Yes,” consent was absent, and the
conduct is likely a violation of this policy.
E. UNDER LEGAL AGE, consent is never present if an individual is under the
legal age of consent (16 in the state of Massachusetts).
XIV. Additional Provisions, Denitions, and Clarications
A. COMPLAINANT: An individual bringing forth a report that they have
experienced one or more alleged policy violations that could constitute
harassment, discrimination, and/or retaliation under these policies.
B. RESPONDENT: An individual who is alleged to have carried out one or
more of the prohibited acts or conduct dened in these policies.
C. ADVISOR: Throughout any investigation or resolution, each party has the
right to consult with an Advisor of their choosing. The advisor may be any
person chosen by the party or appointed by the University. The parties may be
accompanied by their respective advisor at any meeting or proceeding related
to the investigation or resolution of a report under this policy. While the
58 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 59
advisor may provide support and advice to the parties at any meeting and/or
proceeding, the University may establish restrictions regarding the extent to
which the advisor may participate in the proceedings. Advisors may not speak
on behalf of the parties or otherwise participate in, or in any manner, delay,
disrupt, or interfere with meetings and/or proceedings. Generally, the Title
IX Ofce and investigator will communicate directly with the Complainant or
Respondent, and any communications with an advisor may only occur after a
FERPA waiver has been executed. An advisor should plan to make themselves
reasonably available, and the University will not unduly delay the scheduling
of meetings or proceedings based on the advisor’s unavailability. The specic
role of an Advisor differs between the two adjudication processes. Please see
Appendix C for more information.
D. WITNESS: An individual, identied by one or more parties or the investigator,
who has been deemed to have relevant information regarding the investigation.
Witnesses reserve the right to determine whether they would like to participate
in an investigation.
E. EXPERT WITNESS: An individual, identied by one or more parties or the
investigator, who may provide professional opinion regarding evidence discovered in
the independent investigation.
F. LENIENCY (AMNESTY): Individuals may be concerned about reporting
sexual misconduct and gender-based harassment and discrimination,
believing that their own behavior might subject them to disciplinary
action (e.g., a Complainant or witness is underage and was using alcohol
or drugs at the time of the incident). Witnesses and Complainants should
be assured that the focus in matters of sexual misconduct, harassment,
and discrimination is always on the reported behavior, not on whether
someone was, for example, using alcohol or drugs at the time. Individuals
are encouraged to come forward and report such conduct regardless of the
surrounding circumstances. This is also in keeping with Bentley’s medical
amnesty and medical assistance policies.
In situations involving allegations of sexual misconduct, Bentley University
will seek to make the sexual misconduct allegation the primary focus of any
investigation or disciplinary action. In such circumstances, the University
will exercise leniency regarding secondary conduct violations (e.g., underage
drinking), and those issues will not be subjected to adjudication. It should
be noted that the use of alcohol or drugs does not excuse sexual misconduct,
and a person who has been incapacitated through the use of alcohol or drugs
(or by any other means) cannot give effective consent to sexual activity.
G. USE OF ALCOHOL OR DRUGS
A person who has consumed alcohol and/or drugs still has a responsibility
to obtain ongoing consent for any sexual activity with another person. The
use of alcohol or other drugs by the person initiating sexual activity will
never be accepted as an excuse for failing to obtain consent. Please see
Bentley’s denition of Consent, in Section XIII of this document, for more
information.
H. PRESERVING EVIDENCE:
All parties involved in a matter under the Title IX
and Gender-Based Harassment and Discrimination policy should preserve
as much evidence as possible. In addition to any physical evidence that
may be preserved, the following may also be helpful to an investigation
and adjudication process:
■ Any letters
■ Notes
■ Emails
■ Phone calls
■ Videos
■ Photos
■ Text Messages
■ Social media postings (Facebook, Instagram, Twitter, Snaps, etc.),
■ Computer and Phone screenshots
■ Voicemails, or any other form of evidence that may be helpful.
■ Chat room, message boards, blogs
XV. Reporting an Incident
Bentley reafrms the rights of Complainants to decide whether they wish
to be involved in any of the University’s processes to address sex- and
gender-based harassment or discrimination. All involved parties have many
options, including seeking counseling or assistance from a Condential
Resource, making a Formal Report under this policy, and/or making a report
to law enforcement. The University recognizes that deciding among these
options can be difcult and is an intensely personal decision. Individuals
are encouraged to seek assistance and to explore all potential reporting and
support options.
Speaking to the Title IX Coordinator of Deputy Coordinators does not launch
an immediate investigation. A Complainant will always be given various
options for how they would like to proceed, or not proceed.
Individuals may choose to seek action or assistance both on campus as well
as through the surrounding community. Additional or supportive measures
may be provided to remedy the impact of the alleged misconduct as well
as an investigation and adjudication process. The following situations
60 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 61
are an example of reasons why you might choose to report an incident of
misconduct:
■ To seek formal action against someone, such as removing them from a
class or campus
■ To educate the person about their behavior through the use of the
University’s processes and procedures
■ To make Bentley aware of the behavior in case, it is part of a larger
pattern
■ To help prevent similar incidents happening again in the future
■ To confront the individual and make your voice heard about how you
feel about what happened
■ To receive supportive measures such as assistance in changing classes
or other on-campus arrangements
■ To receive support in coping with an incident
A. REPORTING CONFIDENTIALLY: If you are an employee seeking support
but want to maintain condentiality, the best on-campus resources for you
includes speaking with the Ombudsperson as a Condential resource. If you
are a student seeking support but want to maintain condentiality, the best
on-campus resources for you include speaking with Condential resources
within the Health Center, the Counseling Center, the Center for Wellness
and Health Promotion, and the Spiritual Life staff. All of these resources
are included in the cost of attendance for students, and the clinicians in the
Health Center and Counseling Center staff can be seen on an emergency
basis. The off-campus resources listed in Appendix E are also condential
resources. You may consider a condential option if you:
■ Would like to know about support and assistance but are not sure if you
want to pursue formal action against the individual;
■ Have questions or would like to process what happened with
someone without involving police or Title IX procedures/Gender-Based
Harassment and Discrimination procedures; and/or
■ Do not want the Respondent (i.e., alleged violator) to know that you are
seeking help or support
Please be aware that condential resources have some obligations to report,
notably when the individual is in imminent danger or posing imminent
danger to others. There are also obligations to report situations involving
the abuse of a minor. For additional information, please see section IV:
Condentiality, Privacy, and Reporting Responsibilities of Bentley Employees
beginning on page 11 of this policy.
B. INFORMAL RESOLUTION: Individuals may seek an informal resolution
in place of a formal report and investigation. In order to initiate informal
resolution, a Complainant needs to submit a formal complaint. The
University, however, has the discretion to determine whether the nature of
the reported conduct is appropriate for an informal resolution, to determine
the type of informal resolution that may be appropriate in a specic case,
and to refer a report for formal investigation at any time.
Participation in an informal resolution process is voluntary and requires
written consent from all involved parties. The University will not compel
a complaining party or Respondent to engage in an informal resolution,
will not compel a Complainant to directly confront the Respondent, and
will allow a Complainant or Respondent to withdraw from the informal
resolution process at any time. The University may decline the request for
informal resolution in any particular case and may terminate an ongoing
informal resolution process at any time. Pursuing an informal resolution
does not preclude later use of a formal investigation if the informal
resolution fails to achieve a resolution acceptable to the parties and the
University. When the Complainant or the Respondent withdraws from an
informal resolution process, or when an informal resolution is otherwise
terminated for any reason, any statements or disclosures made by the
parties during the course of the informal resolution may be considered in a
subsequent formal investigation
With any informal resolution, each party has the right to choose and consult
with an Advisor. The Advisor may be any person, including an attorney,
who is not otherwise a party or witness to the reported incident(s). The
parties may be accompanied by their respective Advisors at any meeting or
proceeding held as part of the informal resolution. While the Advisors may
provide support and advice to the parties at any meeting and/or proceeding,
they may not speak on behalf of the parties or otherwise participate in,
or in any manner disrupt, such meetings and/or proceedings. Informal
resolutions may include:
i. Resolution with the Assistance of a Neutral Party: A Complainant may seek
assistance in informally resolving a report of prohibited conduct from
the Title IX Coordinator, who can arrange to have a trained, neutral party
facilitate a meeting or meetings between the parties. The availability
of this informal resolution is subject to the agreement of the Title IX
Coordinator, the Complainant , and the Respondent.
ii. Interventions and Remedies: Informal resolution agreements may involve a
host of interventions and remedies, such as actions designed to maximize
the complaining party’s access to educational, extracurricular, and/or
University employment activities; increased monitoring, supervision, and/
or security at locations or activities where the prohibited conduct occurred
62 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 63
or is likely to reoccur; targeted or broad-based educational programming
or training for relevant individuals or groups; academic and/or University
housing modications for involved parties; workplace modications; and/
or any other remedial or protective measures that can be tailored to the
involved individuals to achieve the goals of the Policy.
Any form of informal resolution and any combination of interventions and
remedies may be utilized. If an agreement acceptable to the University,
the Complainant, and the Respondent is reached through an informal
resolution process, the terms of the agreement are implemented, and the
matter is resolved and closed. If an agreement is not reached, and the Title IX
Coordinator determines that further action is necessary, or if a Respondent
fails to comply with the terms of the informal resolution, the matter may be
referred for a formal investigation. The Title IX Coordinator will maintain
records of all reports and conduct referred for informal resolutions. The
Complainant and Responding parties should also know that the Complainant
has the option to bring criminal or civil actions against the Respondent.
C. FORMAL REPORTING OPTIONS: Bentley University encourages all students,
faculty, and staff to le a formal report of an incident to designated campus
ofcials. A list of all responsible employees (those designated ofcials who
have a duty to report incidents of misconduct to the Title IX Coordinator) can
be found in Appendix E of this policy. Reporting to any of these individuals
is considered ofcial notice to the University. After you led a report and
requested an investigation, you should expect the University to investigate
and properly resolve the incident through administrative procedures.
Information disclosed in a formal report will be shared only with individuals
who need to know of the incident, including the incident investigator,
Complainant, Respondent, Advisors, witness(es), and Title IX Coordinators.
Please note that separate protocols exist for criminal reports. If you would
like to le a criminal report, please contact University Police at 781-891-2201.
Please note: University Police will meet with members outside of the Bentley
Police station if requested.
Please note, privacy provisions in Section IX shall apply to a Formal Report.
You may consider ling a report if you:
■ Would like formal action taken. Formal action can include assistance
in obtaining a restraining order or University “No Contact” order, ling
criminal charges, or conduct or employment action for the Respondent
if they are found responsible for violating University policy.
■
Would like the University to be aware of the situation in case it happens
again.
For more information on Title IX and the Gender-Based Harassment and
Discrimination procedures (including investigations and hearings), please
contact the Title IX Coordinator or Deputy Title IX Coordinators. You can also
review the full policy and appendices here.
XVI. Investigation and Adjudication Procedures and Protocols
For information regarding investigation and adjudication procedures and
protocols for reports involving students, please see Appendix C of this policy.
For procedures and protocols for reports involving only faculty and staff,
please see Appendix D of this policy.
XVII. Prevention and Education
Bentley University prides itself on being a leader in providing ongoing
educational programs, annual training, lectures, and initiatives for its
community related to sex/gender-based discrimination risk reduction and
bystander intervention. Examples of these educational efforts include:
■ HAVEN (a mandatory online training that educates and raises
awareness regarding sexual assault for both undergraduate and
graduate students)
■ AlcoholEdu (a mandatory online training that inspires students to
reect on and consider changing their drinking behaviors)
■ Consent Day
■ White Ribbon Campaign
■ Walk a Mile in Her Shoes
■ Guess the Straight Person
■ Bystander training
■ One Love Foundation’s Escalation workshop
■ Hook up culture panels
■ Ally training
■ Documentaries and guest speakers
■ Training around trauma-informed approaches to sexual misconduct
■ Training around sensitivity toward marginalized identities
XVIII. Training of Title IX Coordinators, Investigators, Hearing
Ofcers, Appellate Authorities, Faculty and Staff
The University will provide appropriate training to all Title IX-related
personnel with responsibilities under this policy, including the Title IX
Coordinators, Deputy Coordinators, Investigators, and those with authority
over University Adjudication Processes, and Appeals. The training will be
64 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 65
conducted each academic year and will cover the University’s applicable
prohibited conduct, adjudication processes, due process, and applicable
federal and state laws and regulations. The annual training will also ensure
that all Title IX-related personnel will be able to appropriately address
allegations, provide accurate information to members of the community,
protect the safety, and promote accountability. These training materials are
publicly available on the University’s Title IX and Gender-Based Harassment
& Discrimination website and will be made available for in-person review
upon request.
XIX. Annual Review
This policy is maintained by the Title IX Ofce. The University will review
this policy on at least an annual basis. The review will capture evolving
legal requirements, evaluate the supports and resources available to the
parties, and assess the effectiveness of the resolution processes (including
the fairness of the process, the time needed to complete the process, and the
sanctions imposed). The review may incorporate feedback from parties and
an aggregate view of reports, resolution, and climate..
Appendix A: Campus and Community Resources for Title IX
and Gender-Based Harassment and Discrimination Processes
Bentley University offers various resources for students, staff, and faculty
seeking information or support regarding gender-based discrimination and
harassment.
Bentley also acknowledges that each person experiences and responds in
different ways, and there are a variety of formal and informal options for
support. Please review the information regarding your options for support,
assistance, and reporting so that you can make an informed decision based
on personal needs. Your needs may change over time, so please know that
you may choose to utilize different forms of response at different times.
If you have experienced an act of sex- or gender-based discrimination
or harassment, our rst concern is your safety and well-being. Bentley
University offers some on-campus resources to assist students who have
been affected by sexual violence or sexual misconduct. The greater Boston
area also offers many additional services and support options. Bentley
community members are encouraged to utilize any resource on or off-
campus available to them.
A. ACCOMMODATIONS FOR STUDENTS WITH DISABILITIES. By federal
law, a person with a disability is any person who: 1) has a physical or
mental impairment; 2) has a record of such impairment; or 3) is regarded
as having such an impairment, which substantially limits one or more
major life activities such as self-care, walking, seeing, hearing, speaking,
breathing, or learning. A student requesting an accommodation in
regard to a Title IX investigation/adjudication process must follow the
appropriate process for requesting an accommodation through the Ofce
of Disability Services (located in Jennison Hall). Additionally, the Ofce
of Disability Services can provide students with a comprehensive list
of off-campus resources. The Ofce of Disability Services will make
a determination regarding the request and notify the Title IX staff.
Reasonable accommodations depend upon the nature and degree
of severity of the documented disability. While the Americans with
Disabilities Act of 1990 requires that priority consideration be given to
the specic methods requested by the student, it does not imply that a
particular accommodation must be granted if it is deemed not reasonable
and other suitable techniques are available.
B. SAFETY CONCERNS. Any individual concerned for their immediate
safety on campus can contact University Police at 781-891-3131, and if off-
campus, should contact the local police via 911.
66 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 67
C. THE BENTLEY CARE TEAM: Is a group of professionals from various
departments across campus who are available to provide support,
guidance, or feedback to students responding to allegations of sexual
misconduct. They can help connect students to appropriate resources,
both on and off-campus, when mental, emotional, academic, or physical
well-being is impacted. If you are interested in utilizing the support of
the CARE Team, please visit www.bentley.edu/bentley- cares to submit a
CARE report or call the CARE Team case manager at 781.216.7115.
D. HUMAN RESOURCES. Employees of the institution may consider seeking
support from either the Human Resources department, or the Employee
Assistance Program (EAP). More information about Human 2 Resources
and the EAP can be found at https://www.bentley.edu/ofces/human-
resources, or by calling 781.891.3427. The Human Resources ofces are
located in Rauch 201.
E. CONFIDENTIAL REPORTING/RESOURCES ON CAMPUS. If you are not sure
if you would like to proceed with formal complaint (i.e., ling a police
report or reporting to the University), there are support services available
while you consider those options. The Counseling Center, the Health
Center, and the Spiritual Life staff can be good places to start if you are
not sure whether to report:
■ Bentley Ombudsperson. 781.891.3102. The Ombudsperson is an
independent condential resource available to employees.
■ Bentley EthicsPoint Anonymous Hot Line. 866.384.4277 Bentley has
established a hotline to provide a way to report, anonymously and
condentially, activities that may involve improper conduct, violate
Bentley’s policies or constitutes a violation of law.
■ The Counseling Center. 781.891.2274 (located on the second oor of
the Callahan Police Building). All Staff Members in this ofce are
Condential Resources.
■ The Health Center: 781.891.2222 (located in the basement of Rhodes
Hall). All clinical staff are condential resources
■ The Wellness Center. 781.891.2274 (located on the second oor of the
Callahan Police Building). Prevention staff in the Wellness Center are
trained and Condential Resources.
■ The Spiritual Life Center. 781.891.2418. All ordained ministers are
condential resources. All other staff members are limited reporters
F. FORMAL REPORTING RESOURCES ON CAMPUS. Please contact any of
these ofces if you would like to le a formal report of an incident of sex-
or gender-based discrimination or harassment:
■ Title IX Coordinator and Title IX Staff: 781-891-2161 (located in the
Student Center 320, www.bentley.edu/titleix)
■ The Residential Center: 781-891-2148 (located in the Student Center 320)
■ Bentley University Police (located on the rst oor of the Callahan
Police Building):
■ Non-Emergency: 781-891-2201
■ Emergency: 781-891-3131
G. OFF-CAMPUS/COMMUNITY RESOURCES The following resources are
not managed by Bentley University but may be helpful to individuals,
especially in assisting with a variety of needs that you may have beyond
your campus experience.
Newton-Wellesley Hospital
2014 Washington Street
Newton, MA 02462
617.243.6000
Newton-Wellesley Hospital provides free and condential services for
survivors of domestic and sexual violence. Domestic violence and sexual
trauma affect people of every race, culture, faith, age, gender identity, and
sexual orientation.
Fenway Community Health Center (several locations)
1.888.242.0900
The mission of Fenway Health is to enhance the wellbeing of the lesbian, gay,
bisexual, and transgender community and all people in our neighborhoods
and beyond through access to the highest quality health care, education,
research, and advocacy.
Boston Area Rape Crisis Center (BARCC)
Hotline: 1.800.841.8371
Business: 617.492.9306
BARCC was founded in 1973 to create a hotline to answer calls from rape
survivors. Today, it is a national leader in providing a 24-hour hotline,
24-hour medical advocacy, individual and group counseling, and legal
advocacy. BARCC also provides community awareness and prevention
services. BARCC assists thousands of sexual violence survivors and their
families, friends, and communities each year, regardless of sex, gender
identity, race, physical/developmental disabilities, income, ethnicity, class,
religion, or sexual orientation. Services are provided in English, Spanish,
Haitian Creole, and French, with other languages available upon request.
68 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 69
Casa Myrna
Hotline: 1.877.785.2020
Casa Myrna provides safe housing, legal assistance, counseling, and other
support services for survivors of domestic abuse and relationship violence.
Services are offered in multiple languages.
Rape, Abuse and Incest National Network (RAINN)
Hotline: 1.800.656.HOPE
The Rape, Abuse, and Incest National Network is the nation's largest anti-
sexual violence organization. RAINN operates the national sexual assault
hotline at 1.800.656.HOPE (4673) and the national sexual assault online
hotline at rainn.org. The hotline offers free, condential services. RAINN
educates the public about sexual violence and leads national efforts to
prevent sexual violence, improve services to victims, and ensure that rapists
are brought to justice.
REACH (Refuge, Education, Advocacy, Change)
Hotline: 1.800.899.4000
REACH is committed to advancing the safety, healing, and empowerment
of those who experience domestic or relationship violence through direct
services and education while promoting social justice for individuals
and families of all backgrounds. Based in Waltham, REACH offers free,
community-based supportive services, including support groups, legal and
community advocacy, and child and adolescent therapy.
SANE (Sexual Assault Nurse Examiners)
SANE (sexual assault nurse examiners) are registered nurses and nurse
practitioners who have completed specialized training to assist sexual
assault victims. They perform the pelvic exams and collect all forensic
evidence (think CSI). SANE nurses are available at only specic hospital
emergency rooms. The evidence collected is sealed in Massachusetts
evidence collection kits (rape kits) and sent to a crime lab for evaluation. The
SANE nurse records the victim's account of the assault and can testify at
any legal proceedings. Additionally, the kits can remain condential and are
released to the police only at the victim’s request.
Both the Boston Police Crime Lab and the State Police Crime Lab report that
SANE nurses gather better evidence than non-SANE nurses. Also, having one
person maintain control of all of the rape kit evidence before it gets to the
lab reduces any chance of errors and makes prosecution of the perpetrator
easier. The Massachusetts Department of Health reports that when a SANE
nurse is utilized, a guilty verdict is returned 95 to 100 percent of the time.
Appendix B: Responding to Title IX Allegations
This document serves as a resource for students, faculty, and staff
responding to allegations of sex- or gender-based harassment and
discrimination under one of two adjudication processes: The Title IX Process
or the Gender-Based Harassment & Discrimination (GBHD) Process. A
student, faculty, or staff member who participates in a formal or informal
resolution process under either the Title IX process or the GHBD process will
be referred to as a “Respondent."
Bentley’s Title IX Process and GBHD Process prohibits the
following conduct:
■ Sexual Harassment
■ Sexual Assault
■ Relationship Abuse (Dating/Domestic Violence)
■ Stalking
■ Complicity
■ Exploitation
■ Harassment based on Sexual Orientation, Gender, or Gender Identity
■ Hostile Environment
■ Online and Cyber Misconduct
■ Retaliation
Please note that Bentley has a duty to respond to these incidents regardless
of the presence of alcohol or other drugs.
If a student has alleged that you violated any of the prohibited conduct under
the Title IX and Gender-Based Harassment and Discrimination Policy, this
guide will provide you with some resources and options for preparing for the
upcoming procedures.
Campus Resources
Participating in a Title IX or GBHD resolution process can be a difcult
experience. Bentley has a variety of resources available to support you
through this process. We especially encourage you to utilize services from
condential employees during this process and beyond. Staff who serve
as Condential Employees under Title IX are not required to report any
information about an incident without the responding party's permission.
70 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 71
The following ofces offer condential services for students:
The Counseling Center is a condential, non-judgmental space available for
students who are responding to allegations of sexual misconduct. This ofce
is available to help you process your experience and help you develop the
best course of action going forward. Please call to make an appointment at
781.891.2274 or visit their ofce on the second oor of Callahan Building if
you wish to speak with one of our providers.
The Wellness Center is a condential, non-judgmental space available for
students who are responding to allegations of sexual misconduct. This ofce
is available to help you process your experience and help you develop the
best course of action going forward. Please call to make an appointment at
781.891.2600 or visit their ofce on the second oor of Callahan Building if
you wish to speak with one of our providers
The Health Center provides immediate condential, nonjudgmental medical
care and support during ofce hours for students responding to allegations of
sexual misconduct. The ofce provides emotional support and can facilitate
smooth referrals to counseling services on and off-campus, and then to the
Title IX team if desired by the student. They can be reached during their
ofce hours on the ground oor of Rhodes Hall or at 781.891.2222.
The Spiritual Life Center provides compassionate and condential pastoral
care for students who are responding to allegations of sexual misconduct.
While students do not need a connection to a religious tradition to received
counsel from a Chaplain, faith-based care is provided as desired. Please call
to make an appointment with one of the Chaplain at 781.891.2418
In addition to the condential resources listed above, there are a variety of
ofces and staff members on campus who can offer support but who have a
duty to report incidents to the Title IX staff.
Some of these Ofces include the Multicultural Center, the Center for
International Students and Scholars, the Athletics Department, the
Residential Center, Student Programs & Engagement, Career Services,
Registered Student Organization Advisors, and Faculty Chairs of
Departments.
Finally, the Bentley Care Team is a group of professionals from various
departments across campus who are available to provide support, guidance,
or feedback to students responding to allegations of sexual misconduct. They
can help connect students to appropriate resources, both on and off-campus,
when mental, emotional, academic, or physical well-being is impacted. If you
are interested in utilizing the support of the Care Team, please visit www.
bentley.edu/bentley-cares to submit a Care report or call the Care Team case
manager at 781.216.7115.
Accommodations for Students with Disabilities:
By federal law, a person with a disability is any person who:
1. has a physical or mental impairment;
2. has a record of such impairment; or
3. is regarded as having such an impairment,
which substantially limits one or more major life activities such as self-
care, walking, seeing, hearing, speaking, breathing, or learning. A student
requesting an accommodation in regards to a Title IX or GBHD investigation/
adjudication process must follow the appropriate process for requesting an
accommodation through the Ofce of Disability Services (located in Jennison
Hall).
Additionally, the Ofce of Disability Services can provide students with a
comprehensive list of off-campus resources. The Ofce of Disability Services
will make a determination regarding the request and notify the appropriate
parties. Reasonable accommodations depend upon the nature and degree
of severity of the documented disability. While the Americans with
Disabilities Act of 1990 requires that priority consideration be given to the
specic method requested by the student, it does not imply that a particular
accommodation must be granted if it is deemed not reasonable and other
suitable techniques are available. Please note, staff within the Ofce of
Disability Services are not condential staff members but are responsible
employees with a duty to report disclosures that fall under Title IX or GBHD
policies.
General Rights Under Title IX
As a member of the Bentley community, you are entitled to the following
rights under Title IX:
• Bentley is required to undertake a prompt and thorough investigation
of all reports of gender- and sex-based misconduct. This investigation
is designed to be impartial, and the University utilizes independent,
external investigators to help reduce any bias in the process.
• The Title IX staff can offer supportive measures and reasonable
protective measures to help you continue to live and learn at Bentley
for the duration of the investigation.
• The University has a strict and specic language that protects
against retaliation. You should be able to participate in the Title IX
72 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 73
investigation without facing any form of retaliation.
Preparing for the Investigation Process:
There are several areas for consideration as you prepare for the Title IX
investigation. This section highlights some of those topics and offers some
suggestions for preparation.
1. Document your account of the incident. This can be a stressful
experience, and there may be a great deal of information you would like
the independent investigator to consider in the process. It is often helpful
to record your understanding and recollections of the situation to the
greatest detail possible prior to the meeting with the investigator. Among
the various details in the documentation, consider including previous
communications (e.g., text messages, social media exchanges) and a list
of potential witnesses).
2. You are entitled to an advisor (support person) through the process.
An advisor (support person) can be any person you feel comfortable
conding in, and they do not need to be afliated with the University.
A support person may accompany you to any part of the adjudication
process, including any meetings with the Title IX Coordinator, the
Hearing, and meeting with the independent investigator. The advisor
(support person) does not participate in the process and cannot serve as
a witness to the allegations in the report.
3. Advisor/Support Person of Choice. Some individuals chose to utilize an
attorney as an advisor (support person); you are encouraged to decide
whether that option makes sense for you. As the University process is
administrative, you will never be required to have an attorney in the
Title IX or GBHD investigation/adjudicatory process.
Appendix C: Investigation and Adjudication Procedures and
Protocols for Incidents Involving Students
I. INTRODUCTION AND OVERVIEW:
The University is committed to providing a prompt, thorough, equitable,
and impartial resolution of all reported violations of Title IX and Gender-
Based Harassment and Discrimination Policy (“the Policy”).
Under Title IX Regulations, Universities are required to distinguish
between prohibited conduct that is “under Title IX” and prohibited
conduct that is a violation of other University policies. Therefore, the
University uses two processes to resolve formal reports of prohibited
conduct under this Policy.
The allegation, location of incident, afliation to Bentley, and other
factors can inuence which adjudication process is applied to each case.
One qualifying allegation under the Federal denition of Title IX, even
when allegations applicable under the Gender-Based Harassment &
Discrimination policy are included, will result in the Title IX Adjudication
process.
1. The First Process is dened as the “Title IX Process“ and will only
apply to qualifying allegations of sexual harassment (including
sexual assault, dating violence, domestic violence, and stalking,
as dened in the Policy) involving students. The Title IX Process
involves an investigation, a live hearing (with cross-examination),
adjudication, and, if appropriate, the imposition of sanctions.
In order for a matter to qualify for adjudication under the Title IX
adjudication process, the following must be met:
2. The Second Process is dened as the “Gender-Based Harassment
and Discrimination Process,” known as the “GBHD Process” and
will apply if other allegations are invoked under this policy, based
on other protected class harassment and discrimination that is not
covered in the Title IX Process. Such allegations include, but are
not limited to, sexual exploitation, harassment based on sexual
orientation, gender or gender identity, online misconduct, and
other gender-based harassment and discrimination as dened in
the Policy. The applicable resolution of such offenses, known as the
GBHD Process, can alsoapply to sexual harassment (including sexual
assault, dating violence, domestic violence, and stalking, as dened
above) when jurisdiction does not fall within the Title IX Process, as
determined by the Title IX Coordinator. The GBHD Process involves
an investigation, a three-person panel hearing, adjudication, and, if
appropriate, the imposition of sanctions.
In order for a matter to qualify for adjudication under the GBHD
adjudication process, the reported matter must fall outside of
Appendix C
1
Appendix C: Investigation and Adjudication Procedures and Protocols for Incidents
Involving Students
I. Introduction and Overview:
The University is committed to providing a prompt, thorough, equitable, and impartial
resolution of all reported violations of Title IX and Gender-Based Harassment and
Discrimination Policy (“the Policy”).
Under Title IX Regulations, Universities are required to distinguish between prohibited
conduct that is “under Title IX” and prohibited conduct that is a violation of other University
policies. Therefore, the University uses two processes to resolve formal reports of prohibited
conduct under this Policy.
The allegation, location of incident, affiliation to Bentley, and other factors can influence
which adjudication process is applied to each case. One qualifying allegation under the
Federal definition of Title IX, even when allegations applicable under the Gender-Based
Harassment & Discrimination policy are included, will result in the Title IX Adjudication
process.
1. The First Process is defined as the “Title IX Process“ and will only apply to qualifying
allegations of sexual harassment (including sexual assault, dating violence, domestic
violence, and stalking, as defined in the Policy) involving students. The Title IX Process
involves an investigation, a live hearing (with cross-examination), adjudication, and, if
appropriate, the imposition of sanctions.
In order for a matter to qualify for adjudication under the Title IX adjudication process, the
following must be met:
When is a matter adjudicated under Title IX: Qualifications under the required Federal Definition
• Sexual Harassment
• Sexual Assault
• Relationship Violence
• Stalking
• Incident took place on Bentley’s campus
• Respondent is actively affiliated with Bentley University
at the time of Incident
• Must be deemed as severe, pervasive, AND objectively
offensive to a reasonable person
• Hearing must involve live cross-examination
2. The Second Process is defined as the “Gender-Based Harassment and Discrimination
Process,” known as the “GBHD Process” and will apply if other allegations are invoked
under this policy, based on other protected class harassment and discrimination that is
not covered in the Title IX Process. Such allegations include, but are not limited to, sexual
exploitation, harassment based on sexual orientation, gender or gender identity, online
misconduct, and other gender-based harassment and discrimination as defined in the
Policy. The applicable resolution of such offenses, known as the GBHD Process, can also
74 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 75
allegations of Sexual Harassment, Sexual Assault, Relationship
Violence, or Stalking AND does not qualify under the Title IX
Adjudication process OR when a report involves any alleged violation
of Sexual Exploitation, Harassment based on Sexual Orientation,
Gender, and Gender Identity, Online Misconduct, Complicity, and
Retaliation:
The primary difference between the two processes is the manner in
which the hearing will be conducted during the Adjudication Process.
The manner of how the investigation is conducted will be identical. This
distinction which will be discussed in further detail in this Appendix
All other allegations of misconduct unrelated to incidents covered by the
Policy will be addressed through procedures elaborated in the student,
faculty, and staff handbooks, as discussed in Section V. of the Policy.
Additionally, there may be an option for resolving reports through
an Alternative Resolution. This process includes informal options for
resolving reports. The Title IX Coordinator will determine if this is an
appropriate option for resolution after making an initial assessment
of the reported information, considering the stated interests of the
Complainant and Respondent, campus safety, and the University’s
obligation to maintain an environment free from harassment and
discrimination.
Impacted individuals may also report to law enforcement by ling a
police report with the Bentley Police Department at 781-891-2201 or to
the City of Waltham Police Department 781-893-1212 or to other local law
enforcement authorities.
The processes under this policy are separate and distinct from
Massachusetts’ criminal process. Proceedings under this policy may be
carried out prior to, simultaneously with, or following civil or criminal
proceedings off-campus. Neither a decision by law enforcement
Appendix C
2
apply to sexual harassment (including sexual assault, dating violence, domestic violence,
and stalking, as defined above) when jurisdiction does not fall within the Title IX Process,
as determined by the Title IX Coordinator. The GBHD Process involves an investigation,
a three-person panel hearing, adjudication, and, if appropriate, the imposition of sanctions.
In order for a matter to qualify for adjudication under the GBHD adjudication process, the
reported matter must fall outside of allegations of Sexual Harassment, Sexual Assault,
Relationship Violence, or Stalking AND does not qualify under the Title IX Adjudication
process OR when a report involves any alleged violation of Sexual Exploitation,
Harassment based on Sexual Orientation, Gender, and Gender Identity, Online
Misconduct, Complicity, and Retaliation:
When is a matter adjudication under GBHD: Qualifications under Bentley University Policy
• Sexual Harassment
• Sexual Assault
• Relationship Violence
• Stalking
• Sexual exploitation
• Harassment based on Sexual Orientation,
Gender, Gender Identity
• Online Misconduct
• Complicity
•
Retaliation
• Incident took place off of Bentley’s
campus (i.e. Study Abroad, Off-Campus
House)
• Respondent is actively affiliated with
Bentley University at the time of Incident
• Must be deemed a violation of stated
Bentley University policy
• Hearing does NOT involve a live-hearing
with cross-examination
The primary difference between the two processes is the manner in which the hearing will be
conducted during the Adjudication Process. The manner of how the investigation is
conducted will be identical. This distinction which will be discussed in further detail in this
Appendix
All other allegations of misconduct unrelated to incidents covered by the Policy will be
addressed through procedures elaborated in the student, faculty, and staff handbooks, as
discussed in Section V. of the Policy.
Additionally, there may be an option for resolving reports through an Alternative Resolution.
This process includes informal options for resolving reports. The Title IX Coordinator will
determine if this is an appropriate option for resolution after making an initial assessment of
the reported information, considering the stated interests of the Complainant and
Respondent, campus safety, and the University’s obligation to maintain an environment free
from harassment and discrimination.
Impacted individuals may also report to law enforcement by filing a police report with the
Bentley Police Department at 781-891-2201 or to the City of Waltham Police Department
781-893-1212 or to other local law enforcement authorities.
regarding prosecution nor the outcome of any criminal proceeding will
be considered determinative of whether a violation of this policy has
occurred.
Furthermore, if there is a Concurrent Criminal or Civil Proceedings,
the University will not, as a matter of course, wait for the outcome of
a concurrent criminal or civil justice proceeding to take action on a
Formal Complaint in a University Adjudication Process. The University
has an independent duty to respond to Formal Complaints of sexual
harassment, and discrimination under this Policy.
Bentley also reafrms the rights of Complainants to decide whether
they wish to be involved in any of the University’s processes to address
sex- and gender-based harassment or discrimination. The University
encourages those who wish to receive condential support services
regarding sex- and gender-based discrimination to seek assistance from
staff in the Counseling Center, the Health Center, the Boston Area Rape
Crisis Center, REACH Beyond Domestic Violence, and/or seek medical
attention
II. ADDITIONAL PRELIMINARY INFORMATION
A. Compliance with Bentley University’s Title IX and Gender-Based
Harassment and Discrimination policies and adjudication processes
is a community-wide responsibility. Therefore, the University
expects all members of the University community to cooperate fully
with the investigation and resolution procedures, including but not
limited to attending all requested meetings with the Title IX Team,
investigators, providing all requested information (e.g. schedules,
evidence, etc.) in a timely manner, and active participation in a
hearing, where applicable. In an instance where a Complainant
fails to comply with the stated Adjudication process, the University
reserves the right to dismiss the reported allegations. Should a
Respondent fail to comply with the stated Adjudication process,
the University will continue to reserve the right to render a formal
decision based on the information provided by the complainant
and witnesses. Witnesses are encouraged to cooperate and speak
the truth. In accordance with the University’s core value of honesty,
witnesses who fail to comply with any portion of an adjudication
process may receive appropriate administrative action through the
Student Conduct system.
76 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 77
B. False Information and False Complaints. Any person, who in bad
faith, knowingly les a false complaint under this Policy or provides
materially false information is subject to disciplinary action up
to and including dismissal or separation from the University. A
determination that a Respondent is not responsible for allegations
of Sexual Misconduct does not imply a report, Formal Complaint, or
information provided was false. Similarly, a determination that a
Respondent is responsible for a policy violation does not imply that a
Respondent’s statements disclaiming responsibility were false.
Additionally, participants in the Title IX and Gender-Based
Discrimination Adjudication Process must present, in good faith,
truthful and accurate information to those involved in ensuring
a fair process (including Title IX and Deputy Title IX coordinators,
Independent Investigators, and the Title IX Panel). Knowingly
making false statements or presenting inaccurate information
is unacceptable and will result in a separate disciplinary action
regarding that conduct.
C. Counterclaims. The University is obligated to ensure that the
adjudication process is not abused for retaliatory purposes. The
University permits the ling of counterclaims but uses an initial
assessment, described above, to assess whether the allegations
in the counterclaim are made in good faith. Counterclaims by
the Respondent may be made in good faith, but are, on occasion,
also made for purposes of retaliation. Counterclaims made with
retaliatory intent will not be permitted.
Counterclaims determined to have been reported in good faith will
be processed using the adjudication procedures below. Investigation
of such claims may take place after the resolution of the underlying
initial allegation, in which case a delay may occur.
Counterclaims may also be resolved through the same investigation
as the underlying allegation, at the discretion of the Title IX
Coordinator. When counterclaims are not made in good faith, they
will be considered retaliatory and may constitute a violation of this
policy.
D. Retaliation occurs when an adverse action is taken against an
individual for raising concerns about conduct which is prohibited by
law or policy. All members of the Bentley community have the right
to raise concerns or le a complaint through the student conduct
system without fear of retaliation. Additionally, it is both unlawful
and a violation of University policy to retaliate against an individual
for ling a report of sexual misconduct, gender-based discrimination,
or harassment. Retaliation is also prohibited against anyone who
participates, assisted, or refused to participate in an investigation
or adjudication of sexual misconduct, gender-based discrimination,
and harassment. Acts of alleged retaliation should be reported
immediately to the Title IX Coordinator and will be promptly
investigated. Bentley is prepared to take appropriate steps to protect
individuals who fear that they may be subjected to retaliation.
Examples of retaliation can include hostility, intimidation, threats,
coercion, exclusion, or discrimination directly or indirectly.
Individuals found responsible for violating this policy will face
sanctions that are commensurate with the severity of the violation,
including University expulsion.
Retaliation, or the perception, of, can be committed by any person
who retaliates against
i. anyone ling a report of under this Policy or a Formal
Complaint,
ii. the parties or any other participants (including any witnesses
or any University employee) in the Adjudication Process
relating to a Formal Complaint,
iii. any person who refuses to participate in the Adjudication
Process, or
iv. any person who under this Policy opposed any unlawful
practice is subject to disciplinary action up to and including
dismissal or separation from the University. If any participant
in the Adjudication Process believes they have been
subject to Retaliation (as dened in this Policy), they should
immediately report the alleged retaliatory conduct to the
Title IX Coordinator.
E. Advisors. Throughout any investigation or resolution, each party
has the right to consult with an advisor of their choosing. The
advisor may be any person chosen by the party or appointed by the
University. The parties may be accompanied by their respective
advisor at any meeting or proceeding related to the investigation
or resolution of a report under this policy. While the advisor may
provide support and advice to the parties at any meeting and/or
proceeding, the University may establish restrictions regarding the
extent to which the advisor may participate in the proceedings.
Advisors may not speak on behalf of the parties or otherwise
participate in, or in any manner, delay, disrupt, or interfere with
meetings and/or proceedings. Generally, the Title IX Ofce and
78 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 79
investigator will communicate directly with the Complainant or
Respondent, and any communications with an advisor may only
occur after a FERPA waiver has been executed. An advisor should
plan to make themselves reasonably available, and the University
will not unduly delay the scheduling of meetings or proceedings
based on the advisor’s unavailability. It is important to note that the
specic role of an advisor will vary depending upon the adjudication
method (Title IX/GBHD).
III. TITLE IX COORDINATOR RESPONSE
A. Notice of Complaint/Reporting Incidents
Upon receipt of a complaint or notice to the Title IX Coordinator of an
alleged violation of the Policy from a Complainant or reporting party,
the University will begin a prompt initial assessment to determine
the next steps the University needs to take.
B. Initial Assessment
After receiving a report of prohibited conduct, the Title IX Ofce will
gather information about the reported conduct and respond to any
immediate health or safety concerns raised by the report. Speaking
to the Title IX Coordinator of Deputy Coordinators does not launch an
immediate investigation. A Complainant will always be given various
options for how they would like to proceed, or not proceed. The
Title IX Ofce will assess the Complainant’s safety and well-being,
offer the University’s support measures and assistance. The Title IX
Coordinator will assess the nature and circumstances of the report
to determine whether the reported conduct raises a potential policy
violation, whether the reported conduct is within the scope of this
Policy, and the appropriate manner of resolution under this Policy.
The Title IX Coordinator may consult with the University’s Threat
Assessment Team, or other University administrators as part of the
initial assessment.
As part of the initial assessment, the Title IX Ofce will:
• Assess the nature and circumstances of the report, including
whether it provides the names and/or any other information that
identies the complainant, the respondent, any witness, and/or
any other individual with knowledge of the reported incident;
• Provide the Complainant with written information about
on-and off-campus resources; notify the complainant of the
range of supportive measures available (regardless of whether
they choose to participate in a University or law enforcement
investigation and adjudication process); and their right to an
Advisor.
• Provide the Complainant with an explanation of the procedural
options, works with the Complainant to determine whether the
Complainant prefers a supportive and remedial response, an
informal resolution option (if available), or a formal investigation
and adjudication process through the University.
At the conclusion of the initial assessment, the University will proceed with
one of the following options:
1. Provide supportive measures as a response. This will occur when the
Complainant identied their wishes to received supportive measures
as a response. The Title IX Coordinator will then seeks to facilitate
implementation. The Complainant always has the ability to elect or
initiate an investigation and adjudication later, if desired.
2. Proceed with an investigation under the Title IX Process. This will
occur when a Complainant requests an investigation, and the Title IX
Coordinator determines the misconduct alleged falls within the scope
of Title IX.
3. Proceed with an investigation under the GBHD process. This will
occur when a Complainant requests an investigation, and the Title IX
Coordinator determines that Title IX Process does not apply (and result
in “dismissing a formal complaint under Title IX Process”) and then
refer the matter for appropriate resolution under the GBHD Process.
4. Proceed with an investigation initiated by the Title IX Coordinator. This
will occur when the Title IX Ofce determines that an investigation
must be pursued even when a Complainant requests that no
investigation or adjudication process be pursued; or when Alternative
Resolution is not appropriate or available.
5. Proceed with Alternative Resolution. This option will be available after
the Title IX Coordinator determines if the complaint is suitable for
informal resolution, (and which informal mechanism may serve the
situation best or is available under the circumstances). The Title IX
Coordinator will seek to determine if the Respondent is also willing to
engage in informal resolution.
6. Refer the matter to another appropriate ofce or department for
80 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 81
resolution. If the nature of the allegations is outside the scope of this
policy, the matter will be referred to another appropriate ofce or
department for resolution under the relevant University policy.
7. Close the report with the option to re-open it at another time. If the
Complainant requests resolution or if the University subsequently
determines there is a need to further investigate the alleged
misconduct. This option could include notifying the Respondent of the
alleged misconduct. The level of detail shared will be at the discretion
of the Title IX Coordinator. In these instances, the Respondent will not
be required to make a statement or accept/deny responsibility for the
alleged conduct.
Please note that dismissing a complaint under Title IX Process is just
procedural, and does not limit Bentley’s authority to address a complaint
with an appropriate process and remedies. This process is described in
more detail in Section C of this Appendix.
When the Title IX Coordinator decides to initiate an investigation, impose
supportive measures, or take any other action that impacts a Respondent,
the Title IX Coordinator will also ensure that the Respondent is notied
and receives written information on available resources and options,
consistent with the list outlined above, as applicable.
The Title IX Coordinator will inform and explain the University’s policy
prohibiting retaliation to all parties involved, that the University will
take prompt action when retaliation is reported, and how to report acts of
retaliation.
IV. INVESTIGATION PROCESS
A. Formal Complaint
1. The Complainant must initiate a request for an investigation
and submit it to the Title IX Coordinator. This can be done by
submitting a report through the Title IX and Gender- Based
Harassment & Discrimination online reporting form online
reporting form, sending an email, or otherwise submitting the
request in writing. The Complainant must submit a written
statement setting out the known details of the alleged conduct
that is the subject of the Formal Complaint, including the
following:
• Complainant’s name and contact information;
• Respondent’s name;
• Detailed description of the alleged conduct or event that is
the basis of the alleged violation under this Policy;
• Date(s) and location(s) of the alleged occurrence(s); and
• Names of any witnesses to the alleged occurrence(s); the
resolution sought.
• The Complainant may also submit any documents or
information that is relevant to the Formal Complaint.
The statement and information provided must be written by the
Complainant. The Complainant may also submit additional 3rd party
reports (i.e. University Police reports, reports from the Administrator on
Duty, etc.) to supplement their own written report.
2. The Title IX Coordinator may also initiate a Formal Complaint
against a Respondent (requesting an investigation) and, in doing
so, will initiate the Adjudication Process.
3. The Title IX Coordinator, on behalf of Bentley University, may
also initiate an Inquiry to be conducted by an Independent
Investigator. The purpose of an inquiry is to determine if there is
a policy violation, and if so, which adjudication process the matter
will be adjudicated under.
B. Mandatory and Discretionary Dismissals of Formal Complaint
Under Title IX Regulations, Universities are required to distinguish
between prohibited conduct that is “under Title IX” and prohibited
conduct that is a violation of other University policies (GBHD). Under
Title IX, the University must dismiss a Formal Complaint or the part
of the allegations in a Formal Complaint, if applicable, during the
investigation or hearing where it determines that:
• The conduct alleged in the formal does not meet the
denition of sexual harassment as dened in this policy;
• The alleged conduct did not occur in the University’s
education program or activity; or,
• The alleged conduct did not occur against a person in the
United States.
It is important to note that a dismissal under this provision only
applies to allegations of sexual harassment under Title IX. In such
an instance, the University may still investigate a Formal Complaint
about allegations of sexual harassment as dened under this Policy.
The University may also investigate allegations of prohibited conduct
82 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 83
under this Policy, but it will not technically be “under Title IX
Process.”
The University may dismiss a Formal Complaint, at its discretion,
under this Policy’s Adjudication Process for any of the following
circumstances:
• If the Complainant requests in writing to dismiss a Formal
Complaint (e.g., withdraws the Formal Complaint or any
allegations therein),
• If the Respondent is no longer enrolled or employed by the
University at the time the Formal Complaint is led;
• Any specic circumstances that prevent the University from
gathering evidence sufcient to reach a determination as to
the Formal Complaint or any allegations therein; or
• The conduct alleged does not meet the denition of any
prohibited conduct under this Policy.
If the University dismisses a Formal Complaint, the University must
provide both parties with written notice of the dismissal and the
reason(s) for the dismissal.
C. Notication of Formal Complaint to Respondent
The Title IX Coordinator will provide written notice of a Formal
Complaint to the Respondent when a formal report has been led
against them. The Respondent will be allowed a reasonable time to
respond in writing and through an interview with the investigator.
Initial Meeting. Notice that a formal report has been led against a
Respondent will be provided to that student in person or through
video conference. The Respondent is welcome to bring an advisor to
this initial meeting. At this meeting, the Title IX or Deputy Title IX
Coordinator will discuss the nature of the report, explain the rights
and responsibilities of the Respondent an explain the prohibition
against retaliation, review the investigation and Adjudication Process
and give the responding party a copy of the relevant policies. The
University will provide written notice to a party whose participation
is invited or expected of the date, time, location, participants,
and purpose of all meetings, investigative interviews, or other
proceedings in the Adjudication Process.
Condentiality/Non-Retaliation Acknowledgment. The Complainant
and Respondent will be able to discuss the facts underlying the
subject of the Formal Complaint with counselors, clergy, other
therapeutic professionals, and family. The Complainant and
Respondent should refrain from discussing the Formal Complaint
itself and/or the adjudication process with anyone afliated with
Bentley not related to the Formal Report. This is to preserve the
integrity of the investigative process and also to prevent allegations
of retaliation. Through this acknowledgment, the Complainant
and Respondent also agree to refrain from any retaliatory conduct
against the opposing party or any witnesses in the matter and may
be responsible for any retaliation by persons afliated with the
opposing party (i.e., a friend or family member).
Responding Party's Statement. The Respondent will be allowed a
reasonable time to respond in writing and through an interview
with the investigator. The Respondent may choose to provide a
written response to the Formal Complaint but is not required to do
so. The Respondent’s statement will be submitted to the independent
investigator and serves as an opportunity to respond to the
allegations made by the Complainant. This statement should provide
as much detail as possible about the facts surrounding the alleged
misconduct and must be written by the Respondent.
D. Alternative Resolution Option of Certain Formal Complaints-
Optional
After the parties have been provided a copy of the written notice of
a Formal Complaint, both parties may, in writing, voluntarily agree
to use this Alternative Resolution option, if applicable, at any point
prior to reaching a determination regarding responsibility, but the
parties are not required to do so. The Title IX Coordinator or Deputy
Coordinators will review any request for an Alternative Resolution
and either approve or deny that request based on the reported
behavior and the allegations involved. The Alternative Resolution
entails the parties forgoing the Investigation and Adjudication
Process (including the investigation, report, hearing, adjudication,
and sanctions, if applicable) depending on when the parties agree to
engage in an Alternative Resolution). For example, the Alternative
Resolution may include a mediation process.
At any point prior to agreeing to an Alternative Resolution, each party
has a right to withdraw from the Alternative Resolution process and
resume the Investigation and Adjudication Process with respect to
the Formal Complaint.
E. University Ofcials in the Investigation and Adjudication Process.
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1. Title IX Coordinator. The Title IX Coordinator is the senior
University administrator who oversees the University’s
compliance with the federal law of TitleIX. The Title IX
Coordinator is responsible for the administrative response to
reports and Formal Complaints of harassment, discrimination,
retaliation, and other conduct prohibited under this Policy. The
Title IX Coordinator is available to discuss the Adjudication
Process, coordinate supportive measures, explain University
policies and procedures, and provide education on relevant
issues. The Title IX Coordinator may designate one or more
Deputy Title IX Coordinators to facilitate these responsibilities.
Any member of the University community may contact the Title
IX Coordinator with questions.
2. Investigator. The University will ensure that Formal Complaints
are properly investigated under this Policy by independent
investigators assigned to the Formal Complaint. The
investigators are not Bentley University employees, and are
neutral, impartial fact-nders and gather evidence during the
investigation. The investigators are responsible for completing
an investigation report at the conclusion of the investigation.
The Title IX Coordinators may supervise and advise the
investigators when conducting investigations and to ensure
compliance with Title IX.
3. Hearing Panelist. A Hearing Panelist is responsible for
conducting the hearing in an orderly manner, controlling the
conduct of all participants and attendees of the hearing, and
rendering a written determination regarding the responsibility
of the Respondent’s alleged conduct charges in an impartial,
neutral, and objective manner.
Any of the University Ofcials and individuals listed above who
are materially involved in the administration of the resolution,
investigation, and adjudication process may not have or demonstrate
a conict of interest or bias towards any of the parties.
The Title IX Coordinator will vet the assigned Investigator(s) to
ensure impartiality by ensuring there are no actual or apparent
conicts of interest or disqualifying biases. The parties may, at any
time during the resolution process, raise a concern regarding bias
or conict of interest, and the Title IX Coordinator will determine
whether the concern is reasonable and supportable. If so, another
member will be assigned, and the impact of the bias or conict,
if any, will be remedied. If the source of the conict of interest or
bias is the Title IX Coordinator, concerns should be raised with the
Associate Dean of Student Affairs, John Piga.
The Formal Adjudication Process involves an objective evaluation
of all relevant evidence obtained, including inculpatory evidence
which supports that the Respondent engaged in a policy violation
and exculpatory evidence which supports that the Respondent did
not engage in a policy violation. Credibility determinations may
not be based solely on an individual’s status or participation as a
Complainant, Respondent, or witness.
The University operates with the presumption that the Respondent
is not responsible for the reported misconduct unless and until the
Respondent is determined to be responsible for a policy violation by
the applicable standard of proof.
III. INVESTIGATION PROCESS OF THE FORMAL COMPLAINT – GATHERING
OF EVIDENCE.
After determining that a reported matter will be investigated,
Title IX Coordinator will initiate an investigation, utilizing neutral,
external investigators retained by Bentley. These investigators have
been vetted by the University, are determined to be free from bias,
and well-trained in conducting Title IX investigations. If a party
has concerns regarding the Independent Investigators’ ability to
conduct an unbiased investigation, those must be raised within 72
hours of notice of the Independent Investigator’s name and place of
employment.
It is the responsibility of the investigator, not the parties or their
advisor, to gather the evidence relevant to the formal report and
the facts raised in the parties’ statement, to the extent reasonably
possible. At no time should an Advisor or a Party conduct interviews
with other involved individuals, but instead should provide the
names of those individuals to the investigator for the Investigator
to conduct an interview. During the course of the investigation, the
investigator may utilize some or all of the following procedures, in
whatever order the Investigator deems most appropriate. The scope
of the independent investigation will not be limited to information
provided by the parties or to the violations outlined in the Formal
Complaint. In all cases, the investigator will conduct an adequate,
reliable, and impartial investigation into the allegations of the report,
reviewing all evidence deemed to be relevant. Parties and Witnesses
should make themselves reasonably available to the Investigator.
86 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 87
The Bentley Core Values compel all students to act with integrity and
honesty in their academic, personal, and professional lives. Students
who refuse to cooperate with the Investigator in the independent
investigation, as determined by the Title IX Coordinator, are in
opposition to this core belief and may face disciplinary action for
their refusal to cooperate.
A. Evidence.
The parties in the investigation may present any information
and evidence that may be relevant to the Formal Complaint and
may have an advisor of their choice attend any related interview,
meeting, or proceeding in the Adjudication Process. New evidence
can be submitted to the investigator through the end of designated
Preliminary Investigation Report time period in order to be included
in the Final Investigation Report, and used by the Panel to render
a decision. Advisors are not permitted to actively participate in
meetings or proceedings in the Adjudication Process unless explicitly
outlined in this Policy regarding the Hearing. The parties may
present the names of any fact or expert witnesses who may provide
relevant information, and how the witnesses may be relevant to the
Formal Complaint. The parties may submit to the investigator any
questions they would like asked of any known potential witnesses or
parties.
B. Witness Interviews.
The investigators will interview relevant and available witnesses
or expert witnesses identied by the parties or that the investigator
deems to be relevant to the resolution of the Formal Complaint.
Neither the Complainant nor the Respondent will attend these
interviews.
Witnesses may request from the Title IX or Deputy Title IX
Coordinator a University Advisor to be present with them during
their interview. Prior to being interviewed, a witness will be required
to agree and acknowledge the privacy/non-retaliation agreement not
to disclose or discuss anything relating to the formal report and their
interview with anyone. Through this acknowledgment, the witness
will also agree to refrain from any retaliatory conduct against the
parties or any witnesses in the matter and may be responsible for
any retaliation by persons afliated with them (i.e., a friend or family
member). The investigator will employ best efforts to interview
relevant witnesses who are no longer on campus or in the Boston
area, attempting to contact them by phone, video conference, or email.
Expert Witnesses. The investigator reserves the right to consult with
any experts, which they deem necessary to the determination of the
facts of this case. An expert witness could be consulted to review or
provide a professional opinion regarding evidence discovered in the
independent investigation. Should a Party request that an expert
witness be interviewed by the Investigator, the Title IX Coordinator
or Deputy Coordinators will request that individual’s CV, contact
information, as well as a list of questions that the Party would like
the investigator to ask of the expert witness.
C. Investigation Timeframe.
The investigation of a Formal Complaint can take up to 90 days to
resolve from the ling of a Formal Complaint. There are always
exceptions and circumstances that can cause an investigation to take
longer. There may be delays such as gathering evidence, availability
of the parties and/or witnesses, and University breaks or vacations.
The University will strive to complete the investigation and avoid
delays that are within its control. The parties will be provided
updates on the progress of the investigation, as needed.
D. Access to Evidence.
Once the independent investigation has been completed, the
investigator will evaluate the information obtained during this
process. Prior to the completion of the investigation report, the
investigators will provide access to all evidence obtained (whether
relevant or not) as part of the investigation to both parties (and the
party’s advisor, if any, upon a party’s signed information release for
their advisor of choice). Both parties will have ten (10) days to inspect,
review, and respond to the evidence. All responses to the evidence
must be submitted by the party in writing to the investigator.
Advisors are not permitted to submit written responses to the
evidence on their own or on behalf of the party they are advising.
The investigators will consider all timely responses submitted by the
parties.
The 2020 Federal Regulations protect the privacy of a party’s medical,
psychological, and similar treatment records by stating that a party
must provide written consent to share such materials with the
Bentley University. A Complainant or Respondent can submit medical
documentation as formal evidence, including with their written
consent.
The University will not release copies of evidence, including any
88 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 89
reports related to the incident, outside of the University, except for an
instance in which the University receives a legally issued subpoena.
The Title IX Coordinator and Deputy Coordinators will share reports
with any involved party verbally over a video teleconference or in
person, if available, in the Student Center suite 320. Parties who
read or view reports or evidence in person will be prohibited from
copying, taking pictures, or otherwise disseminating the content.
This is done intentionally to ensure condentiality and privacy.
E. Investigation Report.
The completed investigation report will outline each of the
allegations that potentially constitute prohibited conduct under this
Policy, provide the timeline of the investigation, fairly summarize
the relevant evidence, participant statements, and responses
to questions. The investigator may draw conclusions and make
recommendations regarding the credibility of all testimony and
the reliability of documentation. The investigator will provide
a completed investigation report to the Title IX Coordinator for
review and feedback. The Title IX Coordinator will then provide
the investigation report concurrently to both parties and each
party’s advisor, if any, upon a party’s signed information release for
their advisor of choice at least ten (10) days prior to the date of the
scheduled hearing to review and provide a written response at the
hearing. The Title IX Coordinator will provide a copy of the completed
investigation to the hearing ofcer assigned for the hearing.
V. STANDARD OF EVIDENCE AND PRESUMPTION OF NOT RESPONSIBLE.
The University’s Adjudication Process will use the preponderance of
the evidence standard, which is dened as whether it is more likely
than not that the Respondent violated the Policy as alleged. By law,
it is presumed that the Respondent is not responsible for the alleged
conduct unless that determination regarding responsibility is made
at the conclusion of the Adjudication Process.
VI. REFERRAL FOR HEARING
Provided that the Formal Complaint is not resolved through Informal
Resolution, once the nal investigation report is shared with the
parties, the Title IX Coordinator will refer the matter for a hearing.
A hearing is a Panel that will consist of three Bentley staff members
drawn from a standing pool of panelists. The Panel may consist of
faculty or staff from Bentley University. One of the members will be
the chairperson and will be deemed the Hearing Panel Chair.
The hearing cannot be less than ten (10) days from the conclusion of
the investigation (when the nal investigation report is transmitted
to the parties and the Hearing Ofcer) unless all parties and the
Hearing Ofcer agree to an expedited timeline.
The Title IX Coordinator will select an appropriate Hearing Panel
Chair from the Pool depending on whether the Respondent is an
employee or a student.
VII. HEARING PROCEEDINGS FOR ADJUDICATION UNDER TITLE IX
A. Live Hearing. In accordance with the 2020 Federal Regulations, the
University will provide a live hearing for all Formal Complaints
subject to the Adjudication Process as outlined in this Policy under
the “Title IX Process.”
B. Written Notice of the Hearing. The University will provide at least
ten (10) days written notice to participants of the hearing (and the
participant’s advisor, if any, upon a participant’s signed information
release for their advisor of choice), including the date, time, location,
names of all participants of the hearing (including the Panel
Members and hearing ofcer), and all parties and participants in the
investigation report), the purpose of the hearing, a statement of the
alleged conduct charges, and a summary statement of the evidence
gathered.
B. Challenges to the Panel Members and Hearing Ofcer. Either party
may challenge the fairness, impartiality, or objectivity of the Panel
Members and the Hearing Ofcer. The challenge must be submitted
in writing to the Title IX Coordinator within 72 hours after notice
of the identity of the Panel Members and Hearing Ofcer and must
state the reasons for the challenge. The Title IX Coordinator will
be the sole judge as to whether members can serve with fairness,
impartiality, and objectivity. In the event that the Panel Members or
Hearing Ofcers recuses themselves, an alternative Panel Member
or Hearing Ofcer will be assigned in accordance with the University
procedures.
C. Hearing Panel Chair Duties at the Hearing. The Hearing Panel Chair
will rule on all procedural matters and on objections regarding
exhibits and testimony of participants at the hearing, may question
participants who testify at the hearing, and is entitled to have the
advice and assistance of legal counsel from the Bentley’s General
Counsel or outside Counsel retained by the University.
90 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 91
D. Access to Evidence. Each party will have access to all of the
evidence from the investigation, including a copy of the completed
investigation report.
E. Separate Rooms and Virtual Participation. At the request of either
party, the University will provide the hearing to occur with the
parties located in separate rooms with technology, enabling the
hearing ofcer and the parties to simultaneously see and hear the
participants answering questions. Participants may appear at the
hearing virtually and are not required to be physically present at the
same physical location of the hearing.
F. Opening and Closing Statements: Each party may make opening and
closing statements if they wish.
G. Privileged Information Excluded. No person will be required to
disclose information protected under a legally recognized privilege.
The hearing ofcer must not allow into evidence or rely upon any
questions or evidence that may require or seek disclosure of such
information, unless the person holding the privilege has waived the
privilege. This includes information protected by the attorney-client
privilege.
H. Advisor of Choice. Each party is required, under the Title IX
Regulation, to have an advisor of their choice at the hearing. If a
party does not have an advisor for the hearing, the University will
provide one. The University will appoint a trained Advisor for the
limited purpose of asking questions of the other party and witnesses
necessary at the Hearing. Advisors are not permitted to actively
participate in the hearing, except for asking questions of the other
party and any other witnesses. In addition, witnesses may have an
advisor of their choice at the hearing.
I. Questioning of the participants at the hearing. The Hearing Panel
Chair may, at their discretion, ask questions during the hearing of
any party or witness and may be the rst person to ask questions of
any party or witness. Each party’s advisor will have an opportunity
to ask relevant questions and follow-up questions of the other party
and of any witnesses that participate in the hearing, including
questions that challenge credibility. Each advisor has the ability to
ask questions directly, orally, and in real-time at the hearing. The
parties will not be permitted to personally ask questions of the other
party or any witnesses that participate in the hearing. The advisors
may ask questions under the following procedure:
• The advisor will ask a question of the applicable participant.
• Before the participant answers a question, the hearing ofcer
will rule as to whether the advisor’s question is relevant to the
alleged conduct charges.
• If the Hearing Ofcer rules the advisor’s question as not
relevant, then the hearing ofcer must explain any decision to
exclude a question as not relevant. If the hearing ofcer allows
the question as relevant, the participant will answer it.
J. Prior Sexual History. A Complainant’s sexual predisposition or prior
sexual behavior is not relevant except where questions and evidence
about a Complainant’s prior sexual behavior are offered to prove that
someone other than the Respondent committed the alleged conduct
charged by the Complainant, or if the questions or evidence concern
specic incidents of the Complainant’s prior sexual behavior with
the Respondent and are offered to prove the Complainant’s consent
of the alleged conduct.
K. Not submitting to Cross-Examination. If a party or witness refuses
to submit to any cross- examination questions during the hearing,
the hearing ofcer will not rely on any statement of that party or
witness, when reaching a responsibility determination. The hearing
ofcer will not draw an inference about the determination regarding
responsibility based solely on a party’s or witness’s absence from the
hearing or refusal to answer questions.
L. The hearing will be recorded in audio or audiovisual format and may
be transcribed at the discretion of the University. The recording or
transcript, if applicable, will be available for the parties to inspect
and review, upon request.
M. Format. An example of how a Title IX Hearing will proceed is below:
• Planned for time span to include all witnesses called to
participate (2-3 hours, on average)
• Hearing convenes to introduce all Parties, Advisors, Panelists,
Coordinators, Witnesses
• Review agenda and procedures
• Opening statement from the Investigator summarizing ndings
◊ Panel Chair may pose questions to the investigator
◊ Advisor of Complainant may pose questions of the
92 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 93
investigator through the Panel Chair
◊ Advisor of Respondent may pose questions of the investigator
through the Panel Chair
• Testimony/Opening statement from Complainant
◊ Panel Chair may pose questions of the complainant
◊ Advisor of Respondent may pose questions of the
complainant through the Panel Chair
◊ Advisor of Complainant may pose questions of the
complainant through the Panel Chair
• Testimony/Opening statement from Respondent
◊ Panel Chair may pose questions of the respondent
◊ Advisor of Complainant may pose questions of the
complainant through the Panel Chair
◊ Advisor of Respondent may pose questions of the respondent
through the Panel Chair
• Witness Testimony (the following is replicated for each witness)
◊ Review written testimony of witness
◊ Panel Chair may pose questions of the witness
◊ Advisor of Respondent may pose questions of the witness
through the Panel Chair
◊ Advisor of Complainant may pose questions of the witness
through the Panel Chair
• Remaining questions for Complainant (panel, respondent
advisor, complainant advisor)
• Remaining questions for Respondent (panel, complainant
advisor, respondent advisor)
• Closing Statements
◊ Complainant
◊ Respondent
• Hearing adjourned
VIII.
HEARING PROCEEDINGS FOR ADJUDICATION UNDER GENDER-BASED
HARASSMENT & DISCRIMINATION (GBHD)
The GBHD Adjudication Process will apply in Formal Complaints where
the Respondent is a student at the time of the alleged conduct, and the
alleged conduct did not meet the requirements under the Title IX Process
(as dened by Title IX Regulations and this Policy). The GBHD Process
involves an investigation, a three-person panel hearing, adjudication,
and, if appropriate, the imposition of sanctions. Although, as a general
rule, the University will expect that the parties will participate in the
GBHD hearing, the Panel may proceed without the parties’ presence at
the hearing.
The details of the Hearing under the GBHD Process is detailed below:
A. Investigation Report. Once the independent investigation has been
completed, the Investigator will present the investigation report to Title
IX Coordinator for review and feedback, and then the investigation
report will be reviewed by the GBHD Panel. Both the Complainant and
Respondent will be allowed to review the investigation report prior to the
Panel Hearing.
B. Rebuttal Documentation. After reviewing the investigation report,
the parties have the opportunity to provide any rebuttal statements,
documents, or other new information regarding the sources of
potentially relevant information and/or witnesses in writing to the Title
IX Coordinator within three (3) days of the GBHD Panel. Any information
that is submitted will be made available to the other party for review and
will be provided to the panel.
C. Written Notice of the Hearing. The University will provide at least ten (10)
days written notice to participants of the hearing (and the participant’s
advisor, if any, upon a participant’s signed information release for
their advisor of choice), including the date, time, location, names of all
participants of the hearing (including the Panel Members and hearing
ofcer), and all parties and participants in the investigation report), the
purpose of the hearing, a statement of the alleged conduct charges, and a
summary statement of the evidence gathered.
D. Challenges to the Panel Members and Hearing Ofcer. Either party may
challenge the fairness, impartiality, or objectivity of the Panel Members
and the Hearing Ofcer. The challenge must be submitted in writing to
the Title IX Coordinator within 72 hours after notice of the identity of the
Panel Members and Hearing Ofcer and must state the reasons for the
challenge. The Title IX Coordinator will be the sole judge as to whether
members can serve with fairness, impartiality, and objectivity. In the
event that the Panel Members or Hearing Ofcers recuses themselves,
an alternative Panel Member or Hearing Ofcer will be assigned in
accordance with the University procedures.
E. Hearing Panel Chair Duties at the Hearing. The Hearing Panel Chair will
rule on all procedural matters and on objections regarding exhibits and
testimony of participants at the hearing, may question participants who
94 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 95
testify at the hearing, and is entitled to have the advice and assistance of
legal counsel from the Bentley’s General Counsel
F. Opening and Closing Statements: Each party may make opening
and closing statements if they wish. Any nal statement or rebuttal
documentation must be sent to the Title IX Coordinator within 72 hours
from the Hearing.
G. Privileged Information Excluded. No person will be required to disclose
information protected under a legally recognized privilege. The Hearing
Panel Chair must not allow into evidence or rely upon any questions or
evidence that may require or seek disclosure of such information, unless
the person holding the privilege has waived the privilege. This includes
information protected by the attorney-client privilege.
H. Advisor of Choice. Each party has the option to have an Advisor with
them during the Hearing. Advisors are not permitted to actively
participate in the hearing. In addition, witnesses may have an advisor of
their choice at the hearing.
I. Format. An example of how a GBHD Hearing will proceed is below:
• GBHD Panel convenes via Zoom (15 minutes)
• GBHD Panel will meet with the Investigator via Zoom (30
minutes)
• GBHD Panel will meet with Complainant to hear nal statement
via Zoom (45 minutes)
• GBHD will meet with Respondent to hear nal statement via
Zoom (45 minutes)
• GBHD will meet with Investigator to conclude, if needed, via
Zoom (30 minutes)
• GBHD Panel concludes
THE FOLLOWING POLICY DETAILS ARE IDENTICAL IN BOTH
ADJUDICATION PROCESSES:
IV. INTERFERENCE WITH THE ADJUDICATORY PROCESS. Any person who
interferes with the Adjudication Process outlined in this Policy is subject
to disciplinary action up to and including dismissal or separation from
the University. Interference with the Adjudication Process may include,
but is not limited to:
i. Attempting to coerce, compel, or prevent an individual from
providing testimony or relevant information;
ii. Removing, destroying, or altering documentation relevant to
the Adjudicatory Process; or
iii. Knowingly providing false or misleading information to
the Title IX Coordinator, investigator or hearing ofcer, or
encouraging others to do so.
A. Hearing Panel Determination.
After the panel convenes, the Hearing Panel Chair will issue a written
determination within 7 days of the Hearing, which must include the
following:
• The allegations that potentially constitute prohibited conduct
under this Policy;
• A description of all of the procedural steps of the Adjudication
Process under this Policy (from receipt of a Formal Complaint
to the determination regarding the responsibility of the
Respondent, including any notications of the parties, interviews
with parties and witnesses, site visits, methods used to gather
other evidence, and hearings held);
• The ndings of fact supporting the hearing ofcer’s
determination;
• The conclusion(s) and a rationale as to whether the Respondent is
responsible for each allegation;
• The disciplinary sanctions, if applicable;
• The remedies, if applicable, designed to restore the
Complainant’s access to the education program or activity; and
• The institution’s procedures and permissible bases for the parties
to appeal, if applicable
• The Panel Chair will send a copy of the written determination to
the Title IX Coordinator. The Title IX Coordinator will then share
with the parties simultaneously.
B. Sanctions
Where there is a nding of responsibility, the sanctions and remedies
that are listed below may be considered by the hearing ofcer in
accordance with this Policy. The hearing ofcer may impose one or more
sanctions.
The policy prohibits a broad range of conduct, all of which are serious
in nature. In keeping with the University’s commitment to foster an
environment that is safe, inclusive, and free from discrimination and
harassment, the hearing ofcer has great latitude in the imposition of
sanctions tailored to the facts and circumstances of each report, the
impact of the conduct on the Complainant, surrounding community,
96 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 97
and accountability for the Respondent. The imposition of sanctions is
designed to eliminate prohibited conduct, prevent its recurrence, and
remedy its effects while supporting the University’s educational mission
and federal obligations.
Possible Sanctions for Student Respondents:
1. Written Warning: A formal admonition which appears in an
individual’s disciplinary record at the University. Any further
violation of any University policy, procedure, or directive will result
in more severe sanctions/responsive actions.
2. Educational Training/ Counseling: A requirement to meet with
and engage in a Bentley- sponsored training designed to help the
party become aware of University rules, policies and regulations,
and or external counseling to help students better comprehend the
misconduct and its effects.
3. Probation: A more serious admonition, assigned for a denite
amount of time that identies a student’s status is no longer in good
standing. Probation may also include exclusion from Bentley-owned
or operated property and/or Bentley sponsored events. It also implies
that any future violation, of whatever kind, during that time, may be
grounds for suspension, suspension with conditions, or, in especially
serious cases, expulsion from the University. Probation will be taken
into account in judging the seriousness of any subsequent infraction,
even if the probationary period has expired.
4. Suspension: Termination of student status for a specic period of
time. A party suspended from the university is not to be on campus
unless they received permission from the Ofce of the Dean of
Student Affairs or the appropriate Vice President. Additional
action will be taken against those who trespass, and/or criminal
prosecution for trespassing is possible.
5. Expulsion: A permanent termination of student status at the
University. A party expelled will not have an opportunity for
readmission or a right to be on campus for any reason or to attend
any University activity or program. The individual may not be in or
on any University-owned or leased property. Additional action will
be taken against those who trespass and/or criminal prosecution for
trespassing is possible. Students expelled from the university are not
eligible for a refund of their tuition.
6. Withholding of Degree: In cases involving seniors or graduate
students in their nal semester, the University may withhold a
student's Bentley degree for a specied period of time and/or deny
a student participation in commencement activities. This penalty is
imposed instead of suspension at the end of senior year or nal year
of graduate study when all other degree requirements have been met.
7. Revocation of Degree: The University reserves the right to revoke
a degree previously awarded from the University for fraud,
misrepresentation, and/or other violation of Bentley’s policies,
procedures, or directives in obtaining the degree, or for other serious
violations committed by a student prior to graduation.
8. Other Sanction(s)/Actions: In addition to or in place of the above
sanctions, the University may assign any other sanctions as deemed
appropriate under the circumstances.
9. Suspension of rights and privileges: Including but not limited to the
restriction of access to space, a prohibition from participating in
athletic or extracurricular activities.
a. University Residential Housing/Other Facilities: When
appropriate to the infraction, removal from University
housing or relocation within University housing, or
restrictions other campus facilities.
b. Sanctions will be imposed immediately. The Title IX
Coordinator will review the sanctions recommended by
the hearing ofcer and will consider the appropriateness
of continuing supportive measures on an ongoing basis.
Extended supportive measures may be included in the
sanctions. Students who receive sanctions are not eligible for
a refund of their tuition or housing costs.
POSSIBLE SANCTIONS FOR EMPLOYEE RESPONDENTS:
The appropriate disciplinary authority will determine the sanction,
which may include (in accordance with the employment policies
governing the employee in question):
1. Counseling or Training
2. Warning
3. Employment probation;
4. Job demotion or reassignment of duties;
5. Suspension with or without pay for a specic period of time;
6. Dismissal or termination;
7. Ineligible for rehire; and/or
8. Other sanction(s) or remedies as deemed appropriate under the
circumstances
98 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 99
Sanctions will be determined based on the seriousness of the
misconduct and on the individual's prior disciplinary history
if any. Sanctions will be communicated to the parties, as
appropriate, in writing by the Vice President and Chief Human
Resources Ofcer or designee. The notication will include
the parties' rights of appeal if any. In all cases involving sex
discrimination or sexual misconduct, the le will be archived by
the Title IX Coordinator.
C. Appeals
Either party may appeal in writing the hearing ofcer’s
determination regarding a Respondent’s responsibility under the
Adjudication Process or from the University’s dismissal of a Formal
Complaint (or any allegations in the Formal Complaint) within seven
(7) days of notication of such a determination.
• Appeals are limited on the following basis:
• There has been a failure of fair process.
• New, relevant information that was not available at the time of
the Hearing can be introduced.
• The sanction(s) impose an undue hardship.
The written appeal must specically state the grounds under which
the appeal has been led and must be submitted within the seven
(7) day time limit after their notication of such determination. The
written appeal must set forth the information/evidence to support
the appeal. Appeals that do not comply with these requirements
may not be considered. The appeal is not an opportunity to argue
that the initial decision was wrong or because they disagree with the
nding(s) or sanction(s). The appeal is not a new fact-nding process.
The opposing party will be notied if an appeal has been led. In
some situations, both parties may le an appeal. In this situation,
the appellate administrator will consider and review both appeals
together. Any non-appealing party will have seven (7) days from the
notication of an appeal to submit a written statement.
Both parties will be notied in writing when an appeal is led,
and the appeal procedures will apply equally for both parties. The
person ling the appeal is the Appellant. The appellate ofcer will
be considered by an impartial and well-trained administrator, or
administrators, who were not part of the initial Investigation and
Adjudicatory Process. In considering the appeal, the appellate
administrator(s) will be given the written appeal, the Investigative
Report, including the statements of the Complainant and
Respondent, and the Hearing Ofcer decision to review.
Once the appellate process has been complete, the nal decision will
be provided to both parties.
To submit a written appeal, an Appellant should write a letter to the
Appellate Administrator, the Vice President of Student Affairs, or
their designee, outlining their reason for appeal. The appeal letter
should be submitted via e-mail to:
J. Andrew Shepardson, Ph.D.
Vice President of Student Affairs/Dean of Students at Bentley
University ashepardson@bentley.edu
781-891-2161
The Appellate Ofcer may choose to meet with the party, though
is not requirement will release a written appeal decision within 10
(ten) days from the date of the appeal. The Appeal Decision will be
sent in writing to all parties simultaneously. The Appeal Decision
will specify the nding on each ground for appeal and specify
instructions to:
• Afrm the hearing ofcer’s determination regarding the
Respondent’s responsibility and afrm the disciplinary sanctions
and remedies, if applicable;
• Afrm the hearing ofcer’s determination regarding the
Respondent’s responsibility and amend the disciplinary
sanctions and remedies, if applicable;
• Remand the adjudicatory process back to the hearing stage for
the hearing ofcer to remedy any procedural irregularity or
consider any new evidence;
• Reverse the hearing ofcer’s determination of the Respondent’s
responsibility and amend the disciplinary sanctions and
remedies, if applicable; or
• Afrm or amend the sanctions and/or remedies outlined in the
administrative disposition issued under this Policy.
Any sanctions imposed as a result of the hearing will remain in place
during the appeal process. Any supportive measures may also be
reinstated.
IX. OTHER INFORMATION ABOUT ADJUDICATION PROCESS
A. Adjudication Process Documentation/Record Keeping. The
University’s Title IX Ofce will retain all of the documentation
included in the Adjudication Process for seven (7) years, in
100 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 101
accordance with state and federal records laws and University
policy. All documentation of records is private and condential
to the extent possible under the law. Student records of the
Adjudication Process are disciplinary records under FERPA.
B. Adjudication Process Timeframe. The entire Adjudication Process,
as outlined in this Policy, including any appeal, can take up to
120 days from the ling of the Formal Complaint. However, the
circumstances may require a temporary delay in this timeframe,
and the University may extend this timeframe for a good cause. In
such an instance, the University will provide written notice to the
parties of the delay or extension and the reason(s) for the action.
Good cause may include considerations such as the absence of a
party, a party’s advisor, or a witness; concurrent law enforcement
activity; or the need for language assistance or an accommodation
of disabilities. The time period in this section does not include the
period the parties attempted but failed to reach an agreement in the
Alternative Resolution Process, if applicable, and in such a case, the
Adjudication Process timeframe will be extended by the period the
parties attempted to reach an Alternative Resolution.
C. Safeguarding the Privacy of Complainants and Respondents
Individuals involved in proceedings under this policy are encouraged
to exercise discretion in sharing information in order to safeguard
the integrity of the process and to avoid the appearance of
retaliation. While discretion regarding the process is important,
complainants and respondents are not restricted from discussing
and sharing information with others who may support or assist them
during the process, however they should refrain from sharing any
information with someone not already involved in the process. All
parties, however, are encouraged to maintain the privacy of FERPA-
protected and/or sensitive information gathered or learned in the
process.
In the course of the Adjudication Process, the University may share
information only as necessary with people who need to know in
compliance with the law, which may include but is not limited to
the investigators, witnesses, Complainant, Respondent, parties’
advisors, hearing ofcer, and the appellate ofcer—if applicable.
The University will take all reasonable steps to ensure there is
no retaliation against the parties or any other participants in the
investigation or in any other part of the Adjudication Process.
D. Standard of Review. The Panel Hearing is not intended to serve as
an additional investigatory process. If either party provides any new
and relevant information during their nal statements, it will be
referred to the Title IX Coordinator who will determine, with input
from the Panel Chair, whether or not to implement a supplemental
investigation or separate investigation where the other party will
have a fair opportunity to respond.
E. Supplemental Investigation Procedures. After meeting with the
parties and reviewing any additional information submitted for
consideration, the panel may determine that additional inquiry is
needed in order for a decision to be rendered regarding the Formal
Complaint. If so, the Panel chair will ask that the investigator conduct
a supplemental investigation regarding the areas of concern. The
investigator will focus any additional investigation on the specic
inquiries made by the Panel. The Investigator will then prepare and
submit a supplemental investigation report addressing the ndings
as to the issues raised by the Panel Under ordinary circumstances,
any additional investigation and supplemental investigation report
should be completed and submitted to the Panel within 30 days of
the request for the supplemental investigation. The Panel Chair
reserves the right to schedule a subsequent Panel Hearing to address
the ndings from the supplemental investigation with the parties
separately, at its discretion, should the Panel feel that such a meeting
would be helpful to the process.
F. Withdrawal/Acceptance of Charges
1. Complainant May Withdraw the Report: Prior to the Panel’s
Decision, the Complainant may withdraw the Formal Complaint.
Withdrawal of the report will, under most circumstances, end
the Adjudication Process for that Formal Complaint. Once a
Formal Complaint has been withdrawn, it cannot be led again
by the Complainant within this process. The University reserves
the right to move forward with the Formal Complaint, even after
the Complainant decides to withdraw it, in order to protect the
interests and safety of the Bentley community.
2. Respondent May Accept Responsibility: Prior to the Panel’s
decision, the Respondent may accept responsibility for the
misconduct alleged in the Formal Complaint. This acceptance,
under most circumstances, will end the Adjudication Process,
and the matter would then be referred to the Panel to decide the
issue of the appropriate disciplinary action for the Respondent.
The Panel may take the Respondent’s acceptance of responsibility
into consideration in determining the appropriate sanction. Once
the Respondent accepts responsibility, such acceptance cannot
be withdrawn. A written nding of the accepted report and the
resulting disciplinary action will be issued by the Panel, which
102 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 103
will become part of the Respondent’s student records and will be
shared with the Complainant.
3. Respondent May Withdraw: At any time up until three (3)
days after the Panel Hearing, the Respondent has the right to
withdraw as a student from Bentley University. In such a case,
the Respondent will leave the University with the notation
"Student Withdrew with Disciplinary Charges Pending" on their
disciplinary record. After withdrawing, the Respondent will not
be eligible to return to the University. A Respondent’s withdrawal
will end the Adjudication Process for that report. On the fourth
(4th) day after the Panel Hearing, the Respondent will no longer
be allowed to withdraw, as the pending decision from the panel
and disciplinary action will determine their status with the
University. Under certain circumstances, and at the discretion of
the Panel, the time period for the Respondent to withdraw may
be extended if a supplemental fact-nding investigation has been
requested by the Panel. In that case, the Respondent’s right to
withdraw would expire three (3) days after any subsequent Panel
Hearing is held, or after notice that a subsequent Panel Hearing
will not be scheduled.
G. The Panel's Decision. Upon determining that all of the issues
regarding the formal report have been fully investigated and
adequately addressed, the Panel will render its decision. The
decision will be made on the preponderance of the evidence
standard – which means whether the facts presented in the
investigation report support a nding that it is more likely than
not that University policy has been violated. The decision of
the panel will be reached by a majority. The panel will base its
decision on the information presented in the investigation report
and any supplemental investigation report. Under ordinary
circumstances, the Panel's decision will be issued in writing
within 7 (seven) days after the Panel Hearing. The Panel Chair
will draft the Panel's written decision and submit it to the Title IX
Coordinator.
The Panel may issue the following decisions to a Formal Complaint:
• A nding that a University policy was violated. The panel will
then determine the appropriate sanction(s) for the prohibited
conduct.
• A nding that a University policy was not violated. Based on
this nding, the matter will be considered resolved, and the
investigation will be closed.
• A nding that a University policy was not violated as
there is insufcient evidence to support a nding that the
Respondent violated these policy allegations based on the
Formal Complaint. Based on this nding, the matter will be
considered resolved, and the investigation will be closed.
Appropriate remedial measures (including but not limited to
supportive measures issued to both parties) may, however,
remain in effect.
Where possible, the parties will receive an immediate notication
of the Review Panel's determination. Written notice of the outcome,
sanction (if appropriate), and rationale for each will typically be
provided within 7 days of the hearing. Once the Panel's decision
has been issued, both the Complainant and the Respondent will
be notied by the Title IX staff. Each party will meet with the
Title IX staff separately to receive a copy of the Panel's decision,
referencing the supporting information that the Panel relied on
from the investigation report. The Panel's decision is a condential
document that can only be shared with authorized persons, as
noted in this process (i.e., advisor, support persons, attorneys,
counselors, or clergy). Anyone disclosing the Panel's decision to
a person not authorized to see it shall be subject to disciplinary
action. If the Panel's decision results in disciplinary action which
includes separation from campus, that sanction will be imposed
immediately, regardless of whether an appeal has or will be led.
104 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 105
Sexual Harassment Policy
Respect and community are two key values at Bentley. Bentley strives
to maintain a supportive, civil workplace, one in which employees treat
each other with respect and dignity. In keeping with its values, Bentley
prohibits and does not tolerate sexual harassment against or by anyone in
our community - faculty, staff, students, or anyone else who is working on
campus or visiting. Sexual harassment is prohibited on campus and at any
Bentley-sponsored event whether on- or off-campus. Sexual harassment is
a form of sex discrimination that is unlawful under federal and state law.
If Bentley determines that this policy has been violated, the person found
to have violated this policy may be subject to discipline up to and including
termination.
Bentley University is committed to principles of free speech and upholding
the principles of academic freedom. This policy is not intended to restrict
reaching methods or freedom of expression, nor will it be permitted to do
so. Harassment or discrimination prohibited by this policy is not a proper
exercise of academic freedom.
What is sexual harassment?
Sexual harassment is offensive or unwelcome conduct based on someone's
sex, gender, sexual orientation, or gender identity and/or expression. It
includes offensive or unwelcome sexual advances, requests for sexual favors,
or other verbal or physical conduct of a sexual nature.
Offensive and unwelcome behaviors may constitute sexual harassment
regardless of the intention of the person engaging in the conduct.
While it is not possible to list all behaviors that may constitute sexual
harassment, the following are some examples of conduct that may constitute
sexual harassment:
• Unwanted, persistent requests for dates or for a sexual or personal
relationship
• Requests for sexual favors in exchange for actual or promised job
or academic benets such as favorable reviews, salary increases,
promotions, benets or continued employment
• Sexual jokes
• Use of sexual epithets, written or oral references to sexual conduct,
gossip regarding one's own or another’s sex life, comments on an
individual's body, sexual activity, deciencies, or prowess
• Displaying or sharing sexual objects, pictures or cartoons
• Leering, brushing against the body, sexual gestures, suggestive or
insulting comments
• Inquiries into one's sexual activities
• Assault or coerced sexual acts
If Bentley becomes aware that a violation of this Sexual Harassment Policy
may have occurred, it reserves the right to investigate even if the conduct is
not reported.
Sexual Harassment Training. Bentley requires all employees to complete
an online sexual harassment training program at the time of hire and
periodically thereafter so that we share a common understanding about
what sexual harassment is and how to respond to sexual harassment.
What to do if sexual harassment occurs to you. If you believe that you have
been subjected to sexual harassment, let someone know! If someone at
Bentley in a position to help is not aware of the problem, we can’t make
sure the behavior stops and does not recur. There are several ways sexual
harassment can be addressed –
• Talk to someone, such as your supervisor, division head, HR Business
Partner or the University Ombudsman. These individuals can provide
guidance and coaching on how to approach the person engaging in the
unwanted behavior, or they can counsel you on how to proceed in other
ways. These people may have additional information and may be a
source of support.
• Talk to the person engaging in the behavior, only if you are comfortable
doing so. Explain that their behavior makes you uncomfortable or is
offensive and that you want it to stop. In some cases, the person is not
aware that their behavior is inappropriate or causing offense. However,
not everyone is comfortable having such conversations, so don’t worry if
you would prefer not to go this route.
• File a report of sexual harassment by following the procedure set forth
in How to Report Sexual Harassment or Workplace Discrimination,
Harassment or Bullying. By ling a report, you can either request
informal assistance or a formal investigation, as explained in that
document.
• File an external complaint. While employees are encouraged to
report and resolve sexual harassment
complaints internally,
employees may le a formal complaint with either or
both of the government agencies listed below within their
mandated timeframes.
Mass Commission Against Discrimination
One Ashburton Place, Room 601
Boston, MA 02108
617-994-6000
TTY: 617-994-6198
106 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 107
Equal Employment Opportunity Commission
John F. Kennedy Federal Building
475 Government Center
Boston, MA 02203
1-800-669-4000
TTY: 1-800-669-6820
See something, say something - don’t be a bystander! If you believe that
another employee has been subjected to conduct that violates this policy,
report the conduct immediately to your supervisor or division head, your HR
Business Partner, or the University Ombudsman. If employees do not report
sexual harassment, Bentley may not become aware that such conduct exists
and can’t take steps to ensure that the behavior stops.
What will happen if someone is found to have engaged in sexual
harassment?
At times, employees are reluctant to report sexual harassment because
they think that “nothing will be done” or they “don’t want anyone to
lose their job.” Bentley takes sexual harassment seriously. If a report of
sexual harassment is brought to the attention of Human Resources or the
ombudsman, we will work with you to determine how to proceed. The goal is
to be sure that the harassment stops and does not recur.
Any time an employee may be subject to discipline, the consequence should
be proportionate to the offense. Counseling may be appropriate in some
cases, while termination may be appropriate in other cases. If an employee is
determined to have violated the Sexual Harassment
Policy, Bentley will consider factors such as the nature and severity of the
offense, whether there is a history of prior offenses, and what consequence
will be effective in making sure the behavior stops and does not recur.
Protection from Retaliation. No retaliation will be taken against anyone who
reports sexual harassment, les internal or external harassment complaints,
opposes harassing practices, or participates in the investigation of such
complaints.
Duty of Good Faith. While employees are encouraged to raise issues
regarding sexual harassment, employees may not knowingly or recklessly
make a false complaint of sexual harassment. Any such action may lead to
disciplinary action, up to and including termination of employment.
Categories of Employees
Reporting Responsibilites under Title IX
All involved parties have many options, including seeking counseling or
assistance from a Condential Resource, making a report under this policy,
and/or making a report to law enforcement. The University recognizes that
deciding among these options can be difcult and is an intensely personal
decision. Individuals are encouraged to seek assistance and to explore all
potential reporting and support options.
Please note that faculty and staff members on campus have different roles
and responsibilities for reporting information should a student disclose any
prohibit conduct under this policy. It is important to understand the different
responsibilities of Bentley’s employees. Every employee is designated as
either a Condential Employee, a Responsible Employee, and all Other
Employees.
Condential Employees: This is an employee who may talk to an individual
in condence, and generally only report to the University that an incident
occurred without revealing any personally identifying information.
Disclosures to these employees (e.g., physicians, nurses, professional
counselors, clergy) will not trigger an investigation into an incident against
the individual’s wishes. If a disclosure is made to a Condential Resource,
that employee will only share non-identiable information with the Title
IX Coordinator or Deputy Coordinators. (i.e. 1 count of Sexual Assault,
on-campus, residence hall, month of September). Condential Resources
may be deemed as condential through their professional licensure (i.e.
physicians) or through this policy. Professional Staff within the Center for
Wellness and Health Promotion and the Ombudsperson are deemed as
Condential Employees under this policy.
Responsible Employees: Include faculty and staff, who are required to
notify the Title IX Team when an incident of sexual violence, misconduct,
gender-based harassment, discrimination and/or retaliation is reported to
them, especially if there is cause for fear of a person’s safety. The disclosure
includes the identities of both the Complainant and Respondent (if known)
to the Title IX Coordinator. A report to responsible employees constitutes
a report to Bentley and obligates the University to respond to the incident
and take appropriate steps to address the situation. When a responsible
employee receives a disclosure and noties the Title IX Coordinator, the
Title IX Coordinator or Deputy Coordinators reach out to the Complainant to
108 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 109
provide immediate resources and information, as well as an offer to meet to
discuss options further. A community member will never be forced to speak
with the Title IX Coordinator or Deputy Coordinators until, and if, they would
like to.
All Other Employees: Include faculty members and other Bentley staff
employees who do not fall under the categories of Condential Employees or
Responsible Employees. While these employees do not have any expectation
to keep shared concerns condential and are not required to report those
concerns, the University encourages them to assist an individual who shares
concerns. Individuals may seek advice from any other these employees on
campus after an incident occurs. If you are unsure of someone’s duties and
ability to maintain your privacy, ask them before you talk with them.
This policy is intended to make members of the community aware of the
various reporting and condential disclosure options available to them.
Ideally, this information will inform individuals so they can make deliberate
choices about where to turn should they experience sexual misconduct,
gender-based harassment, discrimination, and/or retaliation. Bentley
encourages impacted parties to talk to someone identied in one or more of
these groups.
Supportive Measures One way in which Bentley will support those who bring
forward claims of sexual misconduct, sex-or gender-based discrimination,
harassment, and retaliation is to offer individualized supportive measures,
without any fee or charge. Supportive measures are non-disciplinary, non-
punitive personalized services offered to parties. The goal of supportive
measures is to provide support to remedy the impact of the alleged
misconduct preserve equal access to education, and protect safety.
Supportive measures are available with or without the ling of a formal
complaint.
Examples of supportive measures include:
Implement contact limitations (“University No Contact Orders”) to all parties
involved
• Changes in housing assignment or room combination
• Assistance from support staff or Academic support services
• Help in rescheduling exams; extensions of a deadline; and other
course-or program-related adjustments
• Limiting access to University facilities and activities pending
resolution of the matter
• Change in class schedule, withdrawal, or leave of absence
• Change in work schedule or job assignment
• Arrangements for counseling, medical, and/or other health services
• Safety planning both on and off-campus
• Providing campus security escorts
• Provide transportation accommodations
• Increased security and monitoring of certain areas of the campus
• Guided conversations to confront behavior
• Action planning to resolve a conict in the future
These are just some examples of the supportive measures that the
University may take to support individuals involved in an incident of
sexual misconduct, sex-or gender-based discrimination, harassment, and
retaliation. As each individual will have their own needs and requests, the
University is committed to tailoring supportive measures to the specics
of each incident, in a fair and equitable manner (without unreasonably
burdening the other party). Individuals seeking to access supportive
measures can contact the Title IX Coordinator or the Deputy Title IX
Coordinators. The decision to impose supportive measures is made at the
discretion of the Title IX Coordinator. The University will also enforce any
orders that are issued by the Courts of the Commonwealth of Massachusetts.
Reporting Condentially
If you are an employee seeking support but want to maintain condentiality,
the best on-campus resources for you includes speaking with the
Ombudsperson as a Condential resource. If you are a student seeking
support but want to maintain condentiality, the best on-campus
resources for you include speaking with Condential resources within the
Health Center, the Counseling Center, the Center for Wellness and Health
Promotion, and the Spiritual Life staff. All of these resources are included in
the cost of attendance for students, and the clinicians in the Health Center
and Counseling Center staff can be seen on an emergency basis. You may
consider a condential option if you:
• Would like to know about support and assistance but are not sure if
you want to pursue formal action against the individual;
• Have questions or would like to process what happened with
someone without involving police or Title IX procedures/Gender-
Based Harassment and Discrimination procedures; and/or
• Do not want the Respondent (i.e., alleged violator) to know that you
are seeking help or support
Please be aware that condential resources have some obligations to
report, notably when the individual is in imminent danger or posing
imminent danger to others. There are also obligations to report situations
involving the abuse of a minor. For additional information, please see
section IV: Condentiality, Privacy, and Reporting Responsibilities of
Bentley Employees beginning on page 11 of this policy.
110 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 111
Condential Resources by Ofce:
If a disclosure is made to a Condential Resource, that employee will only share non-
identiable information with the Title IX Coordinator or Deputy Coordinators. (i.e. 1
count of Sexual Assault, on-campus, residence hall, month of September)
Categories of Employees
Reporting Responsibilities under Title IX
www.bentley.edu/titleix
Appendix E
Confidential Resources by Office:
If a disclosure is made to a Confidential Resource, that employee will only share non-identifiable information with the Title IX
Coordinator or Deputy Coordinators. (i.e. 1 count of Sexual Assault, on-campus, residence hall, month of September)
On-Campus:
Off-Campus:
Available to:
Counseling Center (781-891-2274)
REACH Beyond Domestic Violence
(24/7 Hotline: 1-800-899-4000)
*Satellite office located in Waltham
Full Bentley community:
All students, faculty, staff
Health Center (781-891-2222)
Wellness Center (781-891-2600)
Boston Area Rape Crisis Center
(BARCC) (24/7 Hotline: 1-800-841-8371
Office Phone: 617-492-8306)
*Satellite office located in Waltham
Spiritual Life (781-891-2418)
University Ombudsperson (781-891-3102)
On-Campus Confidential resources by name:
First Name
Last Name
Department
Andrew
Dole
Counseling Center
Hope
Forbes
Counseling Center
Peter
Forkner
Counseling Center
Alexander
Lemiszki
Counseling Center
Linda
MacDougall
Counseling Center
Meghan
Van Keuren
Counseling Center
Dana
Goldberg
Counseling Center
Janelle
Hickey
Counseling Center
Victoria
Koch
Counseling Center
Robert
Kitts
Counseling Center
Alia
Goodheart
Counseling Center
Nora
Basile
Health Center
Jacqueline
Burgoyne
Health Center
Sharon
Donato
Health Center
Anne
Herzog-Rousseau
Health Center
Kimberly
Kerrigan
Health Center
Julia
Matthews
Health Center
Tara
McCauley
Health Center
Deborah
Melchiorri
Health Center
Peter
Bellefeuille
Health Center
Kerry
Hughes
Health Center
Catherine
Vu Morrissey
Health Center
Barry
Ehrlich
Health Center
Margaret
Gillis
Health Center
Rebecca
Parker
Health Center
Zoe
Stern
Health Center
Edward
Brown
Spiritual Life Center
Jeffrey
Foust
Spiritual Life Center
Robin
Olson
Spiritual Life Center
Jessica
Greher-Traue
Wellness
Mallory
Loggins
Wellness
Eliane
Markoff
Office of the President
Categories of Employees
Reporting Responsibilities under Title IX
www.bentley.edu/titleix
Appendix E
Confidential Resources by Office:
If a disclosure is made to a Confidential Resource, that employee will only share non-identifiable information with the Title IX
Coordinator or Deputy Coordinators. (i.e. 1 count of Sexual Assault, on-campus, residence hall, month of September)
On-Campus:
Off-Campus:
Available to:
Counseling Center (781-891-2274)
REACH Beyond Domestic Violence
(24/7 Hotline: 1-800-899-4000)
*Satellite office located in Waltham
Full Bentley community:
All students, faculty, staff
Health Center (781-891-2222)
Wellness Center (781-891-2600)
Boston Area Rape Crisis Center
(BARCC) (24/7 Hotline: 1-800-841-8371
Office Phone: 617-492-8306)
*Satellite office located in Waltham
Spiritual Life (781-891-2418)
University Ombudsperson (781-891-3102)
On-Campus Confidential resources by name:
First Name
Last Name
Department
Andrew
Dole
Counseling Center
Hope
Forbes
Counseling Center
Peter
Forkner
Counseling Center
Alexander
Lemiszki
Counseling Center
Linda
MacDougall
Counseling Center
Meghan
Van Keuren
Counseling Center
Dana
Goldberg
Counseling Center
Janelle
Hickey
Counseling Center
Victoria
Koch
Counseling Center
Robert
Kitts
Counseling Center
Alia
Goodheart
Counseling Center
Nora
Basile
Health Center
Jacqueline
Burgoyne
Health Center
Sharon
Donato
Health Center
Anne
Herzog-Rousseau
Health Center
Kimberly
Kerrigan
Health Center
Julia
Matthews
Health Center
Tara
McCauley
Health Center
Deborah
Melchiorri
Health Center
Peter
Bellefeuille
Health Center
Kerry
Hughes
Health Center
Catherine
Vu Morrissey
Health Center
Barry
Ehrlich
Health Center
Margaret
Gillis
Health Center
Rebecca
Parker
Health Center
Zoe
Stern
Health Center
Edward
Brown
Spiritual Life Center
Jeffrey
Foust
Spiritual Life Center
Robin
Olson
Spiritual Life Center
Jessica
Greher-Traue
Wellness
Mallory
Loggins
Wellness
Eliane
Markoff
Office of the President
On-Campus Condential resources by name:
112 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 113
Categories of Employees
Reporting Responsibilities under Title IX
www.bentley.edu/titleix
Appendix E
All employees within the following offices are considered Responsible Employees:
Responsible Employees are individuals who are required to notify the Title IX Team when an incident of sexual violence,
misconduct, gender-based harassment, discrimination and/or retaliation is disclosed to them
Department:
Division:
Available to:
Athletics
Student Affairs
Full Bentley community:
All students, faculty, staff
Career Services
Center for International Students & Scholars (CISS)
Student Affairs
Cronin Center for International Education
Academic Affairs
Faculty Department Chairs
Academic Affairs
Gender & Sexuality Student Programs
Student Affairs
Graduate Academic Services
Academic Affairs
Graduate Programs & Engagement
Academic Affairs
Human Resources
Multicultural Center
Student Affairs
New Student Programs & Services
Student Affairs
Office of Academic Services
Academic Affairs
Office of Diversity & Inclusion
Office of Student Conduct
Student Affairs
Office of the Vice President of Student Affairs
Student Affairs
Residential Center
Student Affairs
Service Learning
Student Programs & Engagement
Student Affairs
Student Support Services (Care Team)
Student Affairs
University Police
Student Affairs
All employees within the following ofces are considered
Responsible Employees:
Responsible Employees are individuals who are required to notify the Title IX
Team when an incident of sexual violence, misconduct, gender-based harassment,
discrimination and/or retaliation is disclosed to them
Title IX protections of NCAA Athletics
Since its passage, Title IX has dramatically increased athletic opportunities
for women and girls. The Title IX regulation contains specic provisions
governing athletic programs and the awarding of athletic scholarships.
Specically, if an institution operates or sponsors an athletic program,
it must provide equal athletic opportunities for members of both sexes.
In determining whether equal athletic opportunities are available, OCR
considers whether an institution is effectively accommodating the athletic
interests and abilities of students of both sexes.
OCR also considers the following 11 prongs when determining whether male
and female athletes are provided with equivalent benets, opportunities,
and treatment:
1. 1. Equipment and Supplies
2. 2. Game and practice times
3. 3. Travel and per diem allowances
4. 4. Coaching
5. 5. Access to tutoring
6. 6. Locker rooms, practice and competitive facilities
7. 7. Medical and training facilities and services
8. 8. Housing and dining facilities and services
9. 9. Publicity and promotions
10. 10. Support Services
11. 11. Recruitment of Student Athletes
Frequently Asked Questions
How is Title IX applied to athletics?
Athletics programs are considered educational programs and activities.
There are three basic parts of Title IX as it applies to athletics:
1. 1. Participation: Title IX requires that women and men be provided
equitable opportunities to participate in sports. Title IX does not
require institutions to offer identical sports but an equal opportunity to
play;
2. 2. Scholarships: Title IX requires that female and male student-athletes
receive athletics scholarship dollars proportional to their participation;
and
3. 3. Other benets: Title IX requires the equal treatment of female
and male student-athletes in the provisions of: (a) equipment and
supplies; (b) scheduling of games and practice times; (c) travel and
114 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 115
daily allowance/per diem; (d) access to tutoring; (e) coaching, (f) locker
rooms, practice and competitive facilities; (g) medical and training
facilities and services; (h) housing and dining facilities and services;
(i) publicity and promotions; (j) support services and (k) recruitment of
student-athletes.
Does Title IX apply only to athletics?
Although it is the application of Title IX to athletics that has gained the
greatest public visibility, the law applies to every single aspect of education,
including course offerings, counseling and counseling materials, nancial
assistance, student health and insurance benets and/or other services,
housing, marital and parental status of students, physical education and
athletics, education programs and activities, and employment
.
How does an institution comply with Title IX?
An institution must meet all of the following requirements in order to be in
compliance with Title IX:
1. For participation requirements, institutions ofcials must meet one
of the following three tests. An institution may:
• Provide participation opportunities for women and men that
are substantially proportionate to their respective rates of
enrollment of full-time undergraduate students;
• Demonstrate a history and continuing practice of program
expansion for the underrepresented sex;
• Fully and effectively accommodate the interests and abilities of
the underrepresented sex; and,
2. Female and male student-athletes must receive athletics scholarship
dollars proportional to their participation; and,
3. Equal treatment of female and male student-athletes in the eleven
provisions as mentioned above.
Does Title IX benet only girls and women?
Title IX benets everyone -- girls and boys, women and men. The law
requires educational institutions to maintain policies, practices and
programs that do not discriminate against anyone on the basis of gender.
Elimination of discrimination against women and girls has received more
attention because females historically have faced greater gender restrictions
and barriers in education. However, Title IX also has beneted men and boys.
A continued effort to achieve educational equity has beneted all students
by moving toward creation of school environments where all students may
learn and achieve the highest standards.
How is Title IX compliance assessed?
Title IX compliance is assessed through a total program comparison. In
other words, the entire men's program is compared to the entire women's
program, not just one men's team to the women's team in the same sport.
The broad comparative provision was intended to emphasize that Title IX
does not require the creation of mirror image programs. Males and females
can participate in different sports according to their respective interests
and abilities. Thus, broad variations in the type and number of sports
opportunities offered to each gender are permitted.
Does Title IX require that equal dollars be spent on men and women's
sports?
No. The only provision that requires that the same dollars be spent
proportional to participation is scholarships. Otherwise, male and female
student-athletes must receive equitable "treatment" and "benets."
Why does Title IX not require the same amount be spent on men and
women's sports?
The Javits Amendment stated that legitimate and justiable discrepancies
for nongender related differences in sports could be taken into account (i.e.,
the differing costs of equipment or event management expenditures). A male
football player needs protective equipment such as pads and a helmet, and a
female soccer player needs shin guards. Title IX does allow for a discrepancy
in the cost of the equipment as long as both the football and soccer player
received the same quality of equipment.
However, a female ice hockey player must receive the same protective
equipment that a male ice hockey player would receive, since the protective
equipment is the same.
Does Title IX require identical athletics programs for males and females?
Title IX does not require identical athletics programs for males and females.
Rather, Title IX requires that the athletics programs meet the interests and
abilities of each gender. Under Title IX, one team is not compared to the
same team in each sport. OCR examines the total program afforded to male
student-athletes and the total program afforded to female student-athletes
and whether each program meets the standards of equal treatment. Title
IX does not require that each team receive exactly the same services and
supplies. Rather, Title IX requires that the men and women's program receive
the same level of service, facilities, supplies and etc. Variations within
the men and women's program are allowed, as long as the variations are
justied.
116 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 117
Is any sport excluded from Title IX?
Under Title IX there are no sport exclusions or exceptions. Individual
participation opportunities (number of student-athletes participating rather
than number of sports) in all men's and women's sports are counted in
determining whether an institution meets Title IX participation standards.
The basic philosophical underpinning of Title IX is that there cannot be an
economic justication for discrimination. The institution cannot maintain
that there are revenue productions or other considerations that mandate
that certain sports receive better treatment or participation opportunities
than other sports.
Does Title IX mandate that a decrease in opportunities for male athletes be
made in order to provide an increase in opportunities for female athletes?
Title IX does not require reductions in opportunities for male student-
athletes. One of the purposes is to create the same opportunity and quality
of treatment for both female and male student-athletes. Eliminating men
sports programs is not the intent of Title IX. The intent of Title IX is to bring
treatment of the disadvantaged gender up to the level of the advantaged
group.
IMPORTANT TELEPHONE NUMBERS
Bentley University Police
781-891-3131
781-891-2201
781-891-2777
800-841-8371
781-891-2222
781-891-2274
800-899-4000
617-499-5025
617-243-6193
617-243-5590
781-891-2700
781-891-2148
781-891-2194
781-893-1212
781-893-4105
IMPORTANT TELEPHONE NUMBERS
Bentley University Police
Emergencies
Business Line
Alcohol and Other Drug Resource Center
Boston Area Rape Crisis Center Hotline
Health Center
Counseling Center
Domestic Abuse Hotline
Mount Auburn Hospital
Newton-Wellesley Hospital Emergency Room
Newton-Wellesley Urgent Care (Waltham)
Student Programs & Engagement
Residential Center
Spiritual Life Center
Waltham Police (business)
Waltham Fire (business)
118 For emergencies, call 781-891-3131 For information or security services, call 781-891-2201 119
NORTH
CAMPUS
SOUTH
CAMPUS
MAIN ENTRANCE
B54
B55
B56
B58
B52,
B53
B63
B66
B65
B64
LACAVA CENTER
FALCONE WEST
BENTLEY LIBRARY
MORISON HALL
LINDSAY HALL
ADAMIAN ACADEMIC CENTER
NORTH
CAMPUS B
NORTH
CAMPUS C
NORTH
CAMPUS A
NORTH
CAMPUS D
B25
B12
B11
TREE DORMS
STRATTON HOUSE
HARRINGTON HOUSE
B24
SLADE HALL
B45a
B45b
COUNSELING CENTER
UNIVERSITY POLICE
B14
BOYLSTON A AND B
B15
B23
RHODES
HALL
STUDENT CENTER
THE CASTLE
DOVECOTE
FACILITIES/
RECEIVING
B61RAUCH ADMINISTRATION CENTER
B59
JENNISON HALL
B19
B121
B21
MILLER HALL
PRESIDENT’S
HOUSE
FALCONE NORTH
B20
FALCONE EAST
B22
B57
SMITH ACADEMIC TECHNOLOGY CENTER
DANA ATHLETIC
CENTER
COPLEY NORTH
COPLEY SOUTH
FENWAY HALL
B17
KRESGE HALL
B31
B33
B32
ORCHARD NORTH
B35
B34
B37
B41
B43
B39
B42
B38
B36
LEWIS HALL
ORCHARD SOUTH
THE CAPE
ARENA
B16
COLLINS HALL
B18
FOREST HALL
MAIN
CAMPUS
15
minute
parking
15 minute
parking
15 minute
parking
15 minute
parking
L21
L34
L23
L22
L31
L20
L19
L16
L18
L13
L14
L29
L15
L17
L12
L11
BASEBALL FIELD
SOUTH
CAMPUS
QUAD
BASKETBALL
COURT
GREEN
SPACE
COPLEY
CIRCLE
MAIN
CAMPUS
QUAD
FOOTBALL FIELD
LACROSSE
FIELD
TRACK
SOFTBALL FIELD
L3
L2
L1
L6
L4
L45
L46
L44
L47
L5
L7
L8
L9
L27
GENERAL PARKING
L1 LaCava 1
L2 LaCava 2
L3 Rauch
L6 LaCava 3
L7 Morison 7
L8 Morison 8
L9 Morison 9
L20 Arena
L22 Dana 1
L31 Athletics 3
RESIDENT PARKING
L11 Miller 1
L12 Miller 2
L16 Trees
L17 Forest
L19 Stratton
L21 Orchard Decks
L44 North Campus A
L45 North Campus B
L46 North Campus C
L47 North Campus D
FACULTY AND
STAFF PARKING
L13 Police
L18 Slade
L23 Dana 2
L26 Harrington
L29 Student Center
L34 Lewis
FACULTY-ONLY
PARKING
L5 Main Campus
SERVICE AND
VENDOR PARKING
L4 LaCava
L14 Jennison (short-term)
L15 Collins (short-term)
L27 Smith
PARKING LOTS
KEY
= EMERGENCY PHONES
= HANDICAPPED PARKING
= VISITOR PARKING
= AUTHORIZED VEHICLE ACCESS
= VEHICLE GATE
BE AV E R S T R EE T
BE AV E R S T R EE T
FO R EST STR E ET
NO R TH C AM P U S A C CE S S R O A D
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To Trapelo Road
➞
➞
➞
To
Waltham
Center
To Watertown
and Belmont
F
O
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S
T
S
T
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FI E LD ROA D
AC C ESS ROA D
AC C ESS ROA D
NORTH
CAMPUS
SOUTH
CAMPUS
MAIN ENTRANCE
B54
B55
B56
B58
B52,
B53
B63
B66
B65
B64
LACAVA CENTER
FALCONE WEST
BENTLEY LIBRARY
MORISON HALL
LINDSAY HALL
ADAMIAN ACADEMIC CENTER
NORTH
CAMPUS B
NORTH
CAMPUS C
NORTH
CAMPUS A
NORTH
CAMPUS D
B25
B12
B11
TREE DORMS
STRATTON HOUSE
HARRINGTON HOUSE
B24
SLADE HALL
B45a
B45b
COUNSELING CENTER
UNIVERSITY POLICE
B14
BOYLSTON A AND B
B15
B23
RHODES
HALL
STUDENT CENTER
THE CASTLE
DOVECOTE
FACILITIES/
RECEIVING
B61RAUCH ADMINISTRATION CENTER
B59
JENNISON HALL
B19
B121
B21
MILLER HALL
PRESIDENT’S
HOUSE
FALCONE NORTH
B20
FALCONE EAST
B22
B57
SMITH ACADEMIC TECHNOLOGY CENTER
DANA ATHLETIC
CENTER
COPLEY NORTH
COPLEY SOUTH
FENWAY HALL
B17
KRESGE HALL
B31
B33
B32
ORCHARD NORTH
B35
B34
B37
B41
B43
B39
B42
B38
B36
LEWIS HALL
ORCHARD SOUTH
THE CAPE
ARENA
B16
COLLINS HALL
B18
FOREST HALL
MAIN
CAMPUS
15
minute
parking
15 minute
parking
15 minute
parking
15 minute
parking
L21
L34
L23
L22
L31
L20
L19
L16
L18
L13
L14
L29
L15
L17
L12
L11
BASEBALL FIELD
SOUTH
CAMPUS
QUAD
BASKETBALL
COURT
GREEN
SPACE
COPLEY
CIRCLE
MAIN
CAMPUS
QUAD
FOOTBALL FIELD
LACROSSE
FIELD
TRACK
SOFTBALL FIELD
L3
L2
L1
L6
L4
L45
L46
L44
L47
L5
L7
L8
L9
L27
GENERAL PARKING
L1 LaCava 1
L2 LaCava 2
L3 Rauch
L6 LaCava 3
L7 Morison 7
L8 Morison 8
L9 Morison 9
L20 Arena
L22 Dana 1
L31 Athletics 3
RESIDENT PARKING
L11 Miller 1
L12 Miller 2
L16 Trees
L17 Forest
L19 Stratton
L21 Orchard Decks
L44 North Campus A
L45 North Campus B
L46 North Campus C
L47 North Campus D
FACULTY AND
STAFF PARKING
L13 Police
L18 Slade
L23 Dana 2
L26 Harrington
L29 Student Center
L34 Lewis
FACULTY-ONLY
PARKING
L5 Main Campus
SERVICE AND
VENDOR PARKING
L4 LaCava
L14 Jennison (short-term)
L15 Collins (short-term)
L27 Smith
PARKING LOTS KEY
= EMERGENCY PHONES
= HANDICAPPED PARKING
= VISITOR PARKING
= AUTHORIZED VEHICLE ACCESS
= VEHICLE GATE
BE AV E R STR EET
BE AV E R STR EET
FO R ES T S TRE E T
NO RTH CA M PUS AC CES S R O AD
A
L
U
M
N
I
D
R
I
V
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C
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D
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A
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I
R
C
L
E
R
O
A
D
C
O
L
L
E
G
E
D
R
I
V
E
To Trapelo Road
➞
➞
➞
To
Waltham
Center
To Watertown
and Belmont
F
O
R
E
S
T
S
T
R
E
E
T
FI E LD R OAD
AC C ES S R OAD
AC C ES S R OAD
NORTH
CAMPUS
SOUTH
CAMPUS
MAIN ENTRANCE
B54
B55
B56
B58
B52,
B53
B63
B66
B65
B64
LACAVA CENTER
FALCONE WEST
BENTLEY LIBRARY
MORISON HALL
LINDSAY HALL
ADAMIAN ACADEMIC CENTER
NORTH
CAMPUS B
NORTH
CAMPUS C
NORTH
CAMPUS A
NORTH
CAMPUS D
B25
B12
B11
TREE DORMS
STRATTON HOUSE
HARRINGTON HOUSE
B24
SLADE HALL
B45a
B45b
COUNSELING CENTER
UNIVERSITY POLICE
B14
BOYLSTON A AND B
B15
B23
RHODES
HALL
STUDENT CENTER
THE CASTLE
DOVECOTE
FACILITIES/
RECEIVING
B61RAUCH ADMINISTRATION CENTER
B59
JENNISON HALL
B19
B121
B21
MILLER HALL
PRESIDENT’S
HOUSE
FALCONE NORTH
B20
FALCONE EAST
B22
B57
SMITH ACADEMIC TECHNOLOGY CENTER
DANA ATHLETIC
CENTER
COPLEY NORTH
COPLEY SOUTH
FENWAY HALL
B17
KRESGE HALL
B31
B33
B32
ORCHARD NORTH
B35
B34
B37
B41
B43
B39
B42
B38
B36
LEWIS HALL
ORCHARD SOUTH
THE CAPE
ARENA
B16
COLLINS HALL
B18
FOREST HALL
MAIN
CAMPUS
15
minute
parking
15 minute
parking
15 minute
parking
15 minute
parking
L21
L34
L23
L22
L31
L20
L19
L16
L18
L13
L14
L29
L15
L17
L12
L11
BASEBALL FIELD
SOUTH
CAMPUS
QUAD
BASKETBALL
COURT
GREEN
SPACE
COPLEY
CIRCLE
MAIN
CAMPUS
QUAD
FOOTBALL FIELD
LACROSSE
FIELD
TRACK
SOFTBALL FIELD
L3
L2
L1
L6
L4
L45
L46
L44
L47
L5
L7
L8
L9
L27
GENERAL PARKING
L1 LaCava 1
L2 LaCava 2
L3 Rauch
L6 LaCava 3
L7 Morison 7
L8 Morison 8
L9 Morison 9
L20 Arena
L22 Dana 1
L31 Athletics 3
RESIDENT PARKING
L11 Miller 1
L12 Miller 2
L16 Trees
L17 Forest
L19 Stratton
L21 Orchard Decks
L44 North Campus A
L45 North Campus B
L46 North Campus C
L47 North Campus D
FACULTY AND
STAFF PARKING
L13 Police
L18 Slade
L23 Dana 2
L26 Harrington
L29 Student Center
L34 Lewis
FACULTY-ONLY
PARKING
L5 Main Campus
SERVICE AND
VENDOR PARKING
L4 LaCava
L14 Jennison (short-term)
L15 Collins (short-term)
L27 Smith
PARKING LOTS KEY
= EMERGENCY PHONES
= HANDICAPPED PARKING
= VISITOR PARKING
= AUTHORIZED VEHICLE ACCESS
= VEHICLE GATE
BE AV E R S T R EE T
BE AV E R S T R EE T
FO R EST STR E ET
NO R TH C AM P U S A C CE S S R O A D
A
L
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F
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F
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O
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L
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D
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O
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L
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D
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C
L
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I
R
C
L
E
R
O
A
D
C
O
L
L
E
G
E
D
R
I
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E
To Trapelo Road
➞
➞
➞
To
Waltham
Center
To Watertown
and Belmont
F
O
R
E
S
T
S
T
R
E
E
T
FI E LD ROA D
AC C ESS ROA D
AC C ESS ROA D
NORTH
CAMPUS
SOUTH
CAMPUS
MAIN ENTRANCE
B54
B55
B56
B58
B52,
B53
B63
B66
B65
B64
LACAVA CENTER
FALCONE WEST
BENTLEY LIBRARY
MORISON HALL
LINDSAY HALL
ADAMIAN ACADEMIC CENTER
NORTH
CAMPUS B
NORTH
CAMPUS C
NORTH
CAMPUS A
NORTH
CAMPUS D
B25
B12
B11
TREE DORMS
STRATTON HOUSE
HARRINGTON HOUSE
B24
SLADE HALL
B45a
B45b
COUNSELING CENTER
UNIVERSITY POLICE
B14
BOYLSTON A AND B
B15
B23
RHODES
HALL
STUDENT CENTER
THE CASTLE
DOVECOTE
FACILITIES/
RECEIVING
B61RAUCH ADMINISTRATION CENTER
B59
JENNISON HALL
B19
B121
B21
MILLER HALL
PRESIDENT’S
HOUSE
FALCONE NORTH
B20
FALCONE EAST
B22
B57
SMITH ACADEMIC TECHNOLOGY CENTER
DANA ATHLETIC
CENTER
COPLEY NORTH
COPLEY SOUTH
FENWAY HALL
B17
KRESGE HALL
B31
B33
B32
ORCHARD NORTH
B35
B34
B37
B41
B43
B39
B42
B38
B36
LEWIS HALL
ORCHARD SOUTH
THE CAPE
ARENA
B16
COLLINS HALL
B18
FOREST HALL
MAIN
CAMPUS
15
minute
parking
15 minute
parking
15 minute
parking
15 minute
parking
L21
L34
L23
L22
L31
L20
L19
L16
L18
L13
L14
L29
L15
L17
L12
L11
BASEBALL FIELD
SOUTH
CAMPUS
QUAD
BASKETBALL
COURT
GREEN
SPACE
COPLEY
CIRCLE
MAIN
CAMPUS
QUAD
FOOTBALL FIELD
LACROSSE
FIELD
TRACK
SOFTBALL FIELD
L3
L2
L1
L6
L4
L45
L46
L44
L47
L5
L7
L8
L9
L27
GENERAL PARKING
L1 LaCava 1
L2 LaCava 2
L3 Rauch
L6 LaCava 3
L7 Morison 7
L8 Morison 8
L9 Morison 9
L20 Arena
L22 Dana 1
L31 Athletics 3
RESIDENT PARKING
L11 Miller 1
L12 Miller 2
L16 Trees
L17 Forest
L19 Stratton
L21 Orchard Decks
L44 North Campus A
L45 North Campus B
L46 North Campus C
L47 North Campus D
FACULTY AND
STAFF PARKING
L13 Police
L18 Slade
L23 Dana 2
L26 Harrington
L29 Student Center
L34 Lewis
FACULTY-ONLY
PARKING
L5 Main Campus
SERVICE AND
VENDOR PARKING
L4 LaCava
L14 Jennison (short-term)
L15 Collins (short-term)
L27 Smith
PARKING LOTS KEY
= EMERGENCY PHONES
= HANDICAPPED PARKING
= VISITOR PARKING
= AUTHORIZED VEHICLE ACCESS
= VEHICLE GATE
BE AV E R S T R EE T
BE AV E R S T R EE T
FO R EST STR E ET
NO R TH C AM P U S A C CE S S R O A D
A
L
U
M
N
I
D
R
I
V
E
C
E
D
A
R
H
I
L
L
L
A
N
E
L
I
N
D
E
N
S
T
R
E
E
T
F
A
L
C
O
N
W
A
Y
F
A
L
C
O
N
W
A
Y
C
O
L
L
E
G
E
D
R
I
V
E
S
E
R
V
I
C
E
R
O
A
D
F
I
R
E
R
O
A
D
A
C
C
E
S
S
R
O
A
D
C
O
L
L
E
G
E
D
R
I
V
E
C
O
L
L
E
G
E
D
R
I
V
E
C
O
L
L
E
G
E
D
R
I
V
E
C
I
R
C
L
E
R
O
A
D
C
I
R
C
L
E
R
O
A
D
C
O
L
L
E
G
E
D
R
I
V
E
To Trapelo Road
➞
➞
➞
To
Waltham
Center
To Watertown
and Belmont
F
O
R
E
S
T
S
T
R
E
E
T
FI E LD ROA D
AC C ESS ROA D
AC C ESS ROA D
MAIL Bentley University, 175 Forest Street, Waltham, MA 02452 USA
EMAIL ga_universitypolice@bentley.edu
WEB bentley.edu/police
PHONE +1 781-891-2201
FAX +1 781-891-2559
BENTLEY UNIVERSITY is one of the nation’s leading business schools, dedicated to preparing a new kind of business leader — one
with the deep technical skills, broad global perspective, and high ethical standards required to make a difference in an ever-changing
world. Our rich, diverse arts and sciences program, combined with an advanced business curriculum, prepares informed professionals
who make an impact in their chosen elds. Located on a classic New England campus minutes from Boston, Bentley is a dynamic
community of leaders, scholars and creative thinkers. Bentley University Graduate School of Business emphasizes the impact of
technology on business practice, in offerings that include MBA and Master of Science programs, PhD programs in accountancy and
in business, and customized executive education programs. The university enrolls approximately 4,100 full-time undergraduate, 140
adult part-time undergraduate, 1,430 graduate, and 34 doctoral students. Bentley is accredited by the New England Association of
Schools and Colleges; AACSB International — The Association to Advance Collegiate Schools of Business; and the European Quality
Improvement System, which benchmarks quality in management and business education.
09/20BCG.POL.14895
