Title ix
Last modified: December 12, 2025
Sexual Harassment Grievance Policy
1. Introduction and Scope
Title IX of the Education Amendments of 1972 is a federal law prohibiting discrimination on the basis of sex in education programs and activities. This policy applies to students and employees and covers conduct located in the United States within Unbound Academy’s education programs or activities.Unbound Academy (“School,” “the School”) does not discriminate on the basis of sex in its education programs, activities, or employment.
2. Definitions
- Sexual Harassment: Conduct on the basis of sex that satisfies one or more of the following:
a. Quid Pro Quo: An employee conditioning an educational benefit or service on an individual’s participation in unwelcome sexual conduct,
b. Hostile Environment: Unwelcome conduct that a reasonable person would determine is so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the school’s education program or activity,
c. Specific Offenses: Sexual assault, dating violence, domestic violence, or stalking.
- Complainant: An individual who is alleged to be the victim of conduct that could constitute sexual harassment.
- Respondent: An individual who has been reported to be the perpetrator of conduct that could constitute sexual harassment.
- Actual Knowledge: In K-12 schools, the School is considered to have "actual knowledge" (notice) of harassment whenever any employee observes or receives a report of valid allegations.
3. Reporting Sexual Harassment
Any person may report sex discrimination, including sexual harassment, whether or not they are the alleged victim.
- How to Report: Reports may be made in person, by mail, by telephone, or by email using the contact information for the Title IX Coordinator.
- Mandatory Reporting: All K-12 employees must report sexual harassment allegations to the Title IX Coordinator if they witness or hear about an incident.
Title IX Coordinator Contact Information: Erin Williams, erin.williams@unbound.school, (602) 962-8979.
4. Initial Response and Supportive Measures
Upon receiving a report, the Title IX Coordinator will promptly contact the Complainant to discuss the availability of supportive measures.
- Definition: Supportive measures are non-disciplinary, non-punitive, individualized services designed to restore or preserve equal access to education without unreasonably burdening the other party.
- Examples: Counseling, deadline extensions, schedule changes, escort services, mutual no-contact orders, or increased monitoring of certain areas.
- Availability: These measures are available with or without the filing of a formal complaint.
5. Formal Complaint Process
A formal complaint is a document filed by a Complainant (or their parent/guardian) or signed by the Title IX Coordinator alleging sexual harassment and requesting an investigation.
Coordinator-Initiated Complaints: In cases where a Complainant does not wish to proceed, the Title IX Coordinator may sign a formal complaint if necessary to protect the safety of the community (e.g., cases involving patterns of behavior, violence, weapons, or predatory behavior).
6. The Grievance Process (Investigation)
Unbound Academy will follow a grievance process before imposing any disciplinary sanctions against a Respondent.
A. Notice of Investigation and Allegations (NOIA)
Upon receipt of a formal complaint, the School will provide written notice to known parties including:The allegations (identities, conduct, date, and location).A statement that the Respondent is presumed not responsible until a determination is made.A statement that parties may have an Advisor of their choice, who may be an attorney.
B. Investigation StepsBurden of Proof
The burden of gathering evidence rests on the School, not the parties.
- Review of Evidence: Before the investigation report is finalized, the Investigator will send all directly related evidence to the parties and their advisors. Parties have 10 days to inspect, review, and submit a written response.
- Investigative Report: The Investigator will create a report fairly summarizing relevant evidence. This report will be sent to parties and advisors at least 10 days prior to any determination of responsibility for their review and written response.
C. Emergency Removal
Unbound Academy may remove a student Respondent from school on an emergency basis only after conducting an individualized safety and risk analysis determining an immediate threat to physical health or safety exists.
7. Decision-Making and Adjudication
To ensure impartiality, the Decision-Maker cannot be the Title IX Coordinator or the Investigator.
A. Questioning Process (K-12 Model)
A live hearing is optional for K-12 schools. If no hearing is held:After receiving the investigative report, the Decision-Maker must allow each party to submit written, relevant questions to be asked of any party or witness.The Decision-Maker will provide the answers to the parties and allow for limited follow-up questions.
B. Standard of Evidence
The Decision-Maker will determine if a policy violation occurred using the Preponderance of the Evidence standard. This standard will apply to all formal complaints, including those against employees.
C. Written Determination
The Decision-Maker will issue a written determination to both parties simultaneously, which includes:Findings of fact and conclusions for each allegation.Rationale for the determination. Disciplinary sanctions (if applicable) and remedies provided to the Complainant.Procedures for appeal.
8. Sanctions and Remedies
- Sanctions: If a Respondent is found responsible, sanctions may range from warnings and counseling to suspension or expulsion (for students) or termination (for employees).
- Remedies: If a Respondent is found responsible, Unbound Academy must provide remedies to the Complainant designed to restore or preserve equal access to the education program.
9. Appeals
Both parties have the right to appeal the determination or the dismissal of a complaint. An appeal must be based on one of the following grounds:
- Procedural Irregularity: A procedural error that affected the outcome.
- New Evidence: Evidence that was not reasonably available at the time of determination that could affect the outcome.
- Conflict of Interest/Bias: The Coordinator, Investigator, or Decision-Maker had a conflict of interest or bias that affected the outcome.
10. Informal Resolution
At any time after a formal complaint is filed and before a determination is reached, Unbound Academy may offer an informal resolution process (e.g., mediation, restorative practices).
- Voluntary: Both parties must give voluntary, informed, written consent.
- Prohibition: Informal resolution is never allowed to resolve allegations that an employee sexually harassed a student.
- Right to Withdraw: Any party may withdraw from informal resolution and resume the formal grievance process at any time prior to agreeing to a resolution.
11. Retaliation Prohibited
Retaliation is strictly prohibited against any individual for the purpose of interfering with Title IX rights or because the individual made a report, complaint, or participated in a Title IX process. Charges of retaliation will be addressed under separate code of conduct procedures.

