Nondiscrimination Policy

Purchase College is committed to fostering a diverse community of outstanding faculty, staff and students, as well as ensuring equal educational opportunity, employment, and access to service, programs, and activities, without regard to an individual’s race, color, national origin, religion, creed, age, disability, sex, gender identity, sexual orientation, familial status, pregnancy, predisposing genetic characteristics, military status, domestic violence victim status, or criminal conviction. Employees, students, applicants, or other members of the Purchase community (including vendors, visitors, and guests) may not be subjected to harassment that is prohibited by law or treated adversely or retaliated against based upon a protected characteristic.

Purchase complies with all applicable federal and state laws and regulations prohibiting discrimination and harassment. These laws include the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, Title IX of the Education Amendments of 1972, Title VII of the Civil Rights Act of 1964 as Amended by the Equal Employment Opportunity Act of 1972, and the New York State Human Rights Law. These laws prohibit discrimination and harassment, including sexual harassment and sexual violence.

Sexual harassment is defined as: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when:

  1. submission to such contact is made either explicitly or implicitly a term or condition of an individual’s employment or education
  2. submission or rejection of such conduct by an individual is used as the basis for employment or educational decisions affecting the individual
  3. such conduct has the purpose or effect of substantially interfering with an individual’s welfare, academic or work performance, or creating an intimidating, hostile, or demeaning learning or work environment

Sexual harassment may include:

  1. subtle persistent pressure for sexual activity
  2. unnecessary touching, pinching, and/or brushing against a person
  3. sexual coercion or assault
  4. demanding sexual favors with implied or overt threats concerning work or academic decision or preferential treatment
  5. unwelcome verbal/expressive behavior of a sexual nature (e.g., jokes, sounds, obscene phone calls, demeaning graphic portrayals)
  6. stalking, cyber stalking, and failure to accept the termination of a consensual relationship with repeated overtures or other aberrant or negative behavior

Sexual violence has been defined as “physical sexual acts perpetrated against a person’s will or where a person is incapable of giving consent,” including rape, sexual battery, and sexual coercion.

Domestic victim status has been defined by the Human Rights Law as an individual who is a victim of an act which would constitute a family offense under N.Y. Family Court Act § 812. It is unlawful to discriminate against a domestic violence victim in hiring for a job, job advancement, requests for use of leave time, or other terms, conditions or privileges of employment. It is also unlawful for an employer to take an action in retaliation for filing a complaint of discrimination.

Pursuant to the Department of Education’s 2024 Title IX Final Rule, the following are additional protections and expanded definitions applicable to incidents occurring on or after August 1, 2024:

Sex-based harassment is defined as: sexual harassment and other harassment on the basis of sex, including harassment because of gender identity, sexual orientation, sex characteristics, sex stereotypes, and/or pregnancy and other conditions.

Sexual-based harassment may include:

(1) Quid pro quo harassment. An employee, agent or other person authorized by Purchase’s Education Program or Activity explicitly or impliedly conditioning the provision of such an aid, benefit, or service on a person’s participation in unwelcome sexual conduct;

 

(2) Hostile Environment harassment. Unwelcome sex-based conduct that, based on the totality of the circumstances, is subjectively and objectively offensive and is so severe or pervasive that it limits or denies a person’s ability to participate in or benefit from Purchase’s Education Program or Activity (i.e., creates a Hostile Environment). Whether a Hostile Environment has been created is a fact-specific inquiry that includes consideration of the following: (i) the degree to which the conduct affected the Complainant’s ability to access Purchase’s Education Program or Activity; (ii) the type, frequency, and duration of the conduct; (iii) the Parties’ ages, roles within Purchase’s Education Program or Activity, previous interactions and other factors about each Party that may be Relevant to evaluating the effects of the conduct; (iv) the location of the conduct and the context in which the conduct occurred; and (v) other Sex-Based Harassment in Purchase’s Education Program or Activity;

 

(3) Sexual Assault (as defined in the Clery Act, 20 U.S.C. 1092(f)) means any sexual act directed against another person, without the Consent of the victim, including instances where the victim is incapable of giving Consent;

 

(4) Dating Violence (as defined in the Violence Against Women Act (VAWA) Reauthorization of 2022 and the VAWA Amendments to the Clery Act) means any violence committed by a person: (A) who is or has been in a social relationship of a romantic or intimate nature with the victim; and (B) Where the existence of such a relationship shall be determined based on a consideration of the following factors: (i) The length of the relationship; (ii)the type of relationship; and (iii) the frequency of interaction between the persons involved in the relationship.

 

(5) Domestic Violence means any felony or misdemeanor crimes committed by a person who: (A) is a current or former partner of the victim under the family or Domestic Violence laws of New York, or a person similarly situated to a spouse of the victim; (B) is cohabitating, or has cohabitated, with the victim as a spouse or intimate partner; (C) shared a child in common with the victim; or (D) commits acts against a youth or adult victim who is protected from those acts under the family or Domestic Violence laws of New York; or

 

(6) Stalking means engaging in a course of conduct directed at a specific 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.

On-campus inquiries or complaints regarding violations of the Nondiscrimination Policy or Title IX may be addressed to:

Arletha Miles-Boyce, J.D.
Affirmative Action/Chief Diversity Officer, Title IX Coordinator and ADA Compliance Officer
Purchase College
735 Anderson Hill Road
Purchase, NY 10577
(914) 251-5992
Lisa.milesboyce@purchase.edu

David Sparnroft
Assistant Affirmative Action and Title IX Investigator

Purchase College
735 Anderson Hill Road
Purchase, NY 10577
(914) 251-5982
david.sparnroft@purchase.edu

Inquiries may also be directed to:

New York Office for Civil Rights
U.S. Department of Education
32 Old Slip, 26th Floor
New York, NY 10005-2500
Tel: (646) 428-3800, Fax: (646) 428-3843
TDD: (800) 877-8339
OCR.NewYork@ed.gov