September 30, 2019

Spotlight #002: An Interview with Michelle Disson, Title IX and ADA Coordinator, Florida Polytechnic University

At a small, fresh institution like Florida Polytechnic University — which opened for instruction in 2014 and has fewer than 2,000 students, faculty and staff — establishing a campus culture that upholds Title IX protections, along with other equity missions, is crucial. Michelle Disson serves as Florida Polytechnic’s Title IX and ADA Coordinator. When it comes to Title IX, Disson said she is “a party of one.”

“I do everything from initial intake at this moment, I do investigations, I do the training,” Disson said, “and I oversee the programming as well.”

With ADA compliance, Disson oversees other campus offices the Office of Disability Services, facilities and human resources to ensure the appropriate policies and procedures are followed. The intersection of Title IX and ADA compliance is centered on giving students equitable experiences.

“We want to make sure that students can continue their educational journey and have options and resources,” Disson said. “With the ADA, you want to make sure that everyone’s treated fairly and has an equal opportunity to continue their education and experience programs and activities within the university.”

Those options and resources, Disson said, present themselves through various student-life-centric offices like Florida Polytechnic’s Academic Success Center, Counseling Services and CARE Services, which handles student health and wellness along with crisis and safety concerns.

Those campus resources are supplemented with online information about Title IX and a reporting tool available on Florida Polytechnic’s website.

Florida Polytechnic provides Title IX education and training, Disson said, for students, faculty and staff. Each year, Florida Polytechnic employees complete Title IX training through Get Inclusive. New employees also receive training in their new hire orientation as well.

“For students, we are involved in orientation,” she said. “All of the new students who attend orientation get the training … They are provided, from Get Inclusive, Voices for Change. So, all students have to complete Voices for Change before they’re allowed to register for the following semester.”

In addition to the student body’s education through Voices for Change, Disson provides open sessions for faculty to learn more about Title IX obligations and programming for students on topics like healthy relationships, sex education, sexual violence prevention and intimate partner violence prevention.

With Get Inclusive, Disson said they are the only system she has implemented that receives positive feedback.

“Most people understand that, yeah, I have to do this every year, especially the employees,” Disson said. “But I typically hear, ‘This was horrible, this takes so much time, I didn’t really get anything out of it.’ With Get Inclusive, I have found more people recognizing … it got the point across, and ‘Hey, I’m remembering now I need to do this. I have this exact scenario.’”

Disson added that she appreciates the types of questions that are asked in the training modules. Evaluating answers to open-ended prompts allows her to identify what is important to students and learn more about them.

“I was very hesitant in the beginning of my time with Get Inclusive of the many open-ended questions,” she said. “I have found that has been almost invaluable when I go through them, just even [to] get a sense of what is the tone … that has been very helpful with students. I learned so much about our student population that you wouldn’t typically get from a first-year experience survey.”

Moving forward, Disson said Florida Polytechnic hits a lot of aspects in regard to Title IX compliance and education, with Get Inclusive in that mixture of resources. A goal she identified: continuing to get information out to students and remind faculty about reporting options. Progressing this outreach harkens back to the inherent values of Title IX and ADA.

“It is important to provide an equitable experience for students,” Disson said.

September 2, 2019

Anonymous Workplace Reporting: How to Make it Effective

Anonymous and confidential reporting mechanisms help foster a climate whereby company employees are more likely to report or seek guidance regarding potential or actual wrongdoing without fear of retaliation.”

—Elements of an Effective Whistleblower Hotline, Harvard Law School Forum on Corporate Governance and Financial Regulation 

An anonymous reporting system is not a panacea that will magically convince employees to overcome their fears about coming forward to report harassment, discrimination, and other workplace misconduct. There will always be individuals who prefer to talk to their managers face-to-face. At the other end of the spectrum, some people will never come forward to report what they’ve experienced or witnessed, no matter how robust their company’s anti-harassment program is.

For everyone in between, an anonymous way to report misconduct is a vital cog in any workplace ethics and compliance program. The U.S. Equal Employment Opportunity Commission (EEOC) makes the case for anonymous reporting in its “Select Task Force on the Study of Harassment in the Workplace” report. It states that “effective reporting systems for allegations of harassment are among the most critical elements of a holistic anti-harassment effort” and specifies that a path to anonymous reporting must be a part of any comprehensive reporting system

This is because the fear of retaliation is a major factor driving the woeful lack of reporting. An estimated 90 percent of people who have experienced harassment never initiate formal action, such as reporting a complaint or filing a charge, the EEOC reports. 

In its report “Elements of an Effective Whistleblower Hotline” the Harvard Law School Forum on Corporate Governance and Financial Regulation found that “In companies with an internal hotline, tips account for over half of all fraud detection versus only one-third of detections in companies with no internal hotline. Notably, the rate of discovering fraud “by accident” more than doubles when a company fails to offer a hotline.”

Create a Speak-Up Culture

One of the five principles of a high-quality ethics and compliance program is encouraging a “Speak Up” culture, according to the Ethics and Compliance Initiative, which it defines as an organization that “encourages, protects and values the reporting of concerns and suspected wrongdoing.”  When employees felt encouraged to make their voices heard, even when it was with bad news, favorable ethics outcomes increased by 14 times, according to the ECI report, entitled “Measuring The Impact Of Ethics & Compliance Programs.”

Communicate, Communicate, Communicate

The ECI report found that other critical actions a company can take that result in favorable outcomes involve the company’s communication about the anonymous reporting system. It lists the following key ways a business should behave in order to encourage reporting from its employees.

  • Company Responds in a Timely Manner after Reporting;
  • Management Keeps Employees Informed After Reporting, and
  • Company Explains Reporting Procedure/Process. 

All these points underscore the fact that a company is unlikely to reap benefits from an anonymous reporting system unless they actively communicate on its behalf and respond quickly to any reports they receive. 

Constantly Evaluate

The Harvard Law School Forum on Corporate Governance and Financial Regulation states that companies must constantly and actively evaluate their anonymous reporting systems to ensure their success. The forum states that evaluation is required to ensure they  “are operating as intended and are effective in preventing and identifying unethical or potentially unlawful activity, including corporate fraud, securities violations and employment discrimination or harassment. This evaluation should be a key element of every company’s assessment of its compliance and ethics program.”

The report goes on to list key factors necessary to make anonymous reporting systems such as whistleblower hotlines effective. They include:

  • Ensuring anonymity and confidentiality. (Read more about how anonymous reporting works here.)
  • Preventing retaliation against those who report wrongdoing. (Read about why so few employees report wrongdoing.)
  • Publicizing the hotline. 
  • Creating multiple uses for the hotline, including a helpline. (Learn more about how anonymous reporting systems can go beyond capturing just harassment.)
  • Recording and analyzing statistics. 
  • Benchmarking compliance programs to internal and external data sources. 
  • Hiring a third-party provider to manage the hotline.  
  • Allowing multiple methods for submitting tips. (Read about why multiple reporting channels are needed.)
  • Evaluating, testing and auditing the reporting systems. 

All the major studies show that a company cannot implement an anonymous reporting system and then sit by passively and assume that it will work. The business must play an active role in ensuring its success by encouraging people to speak up and then communicating about and closely evaluating to systems that have been put in place to prevent harassment and discrimination in the workplace. (Read more about best practices for anonymous workplace reporting systems.) 

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