Bias, Discrimination, & Harassment

All Policies › Administration & Operations › Bias, Discrimination, & Harassment

Responsible Office

University President

Policy Owner

Vice President for Strategic Operations & Human Resources

Policy Contact

Vice President for Strategic Operations & Human Resources

Issued

2020-02-18

Last Revised

2026-10-01

On this page: Policy Statement · Reason for Policy · Policy Scope · Procedures · Frequently Asked Questions · Forms · Appendices · Additional Contacts · Definitions · Responsibilities · Related Information · History

Policy Statement

North Central University is committed to maintaining a Christ-centered community in which all members of the North Central University community are treated with respect and dignity, free from bias, discrimination, and harassment.

As a faith-based institution, the university is exempt from certain laws and regulations concerning discrimination and maintains the right, with regard to admissions, enrollment, employment, and other matters, to uphold and apply its religious beliefs related to, among other issues, marriage, sex/gender, gender identity, sexual orientation and sexual activity.

Among other forms of discrimination, the university prohibits sex discrimination in accordance with Title IX, including sexual assault and sexual harassment. Sexual misconduct is a form of sex discrimination and includes a variety of unwelcome behavior of a sexual nature, including gender-based harassment, sexual harassment, sexual violence, and sexual assault. The university does not, in accordance with Title IX, discriminate on the basis of sex in its employment, education, educational, extracurricular, athletic, or other programs. The university will promptly and equitably respond to all reports of sexual misconduct in order to eliminate the misconduct, prevent its recurrence, and address its effects on any individual or the community.

Reporting

Reports of incidents of bias, discrimination, or harassment are made to the university through an employee or through the electronic Bias Incident Form.

While the university encourages all campus community members to report incidents, university employees must report actual or suspected incidents of bias, discrimination, or harassment. When a report comes directly to an employee, the individual reporting is asked to fill out the incident report form.

Those with reporting responsibilities under this section must not undertake to investigate potential policy violations on their own and, instead, must report the potential policy violation as soon as possible in accordance with this policy, providing all known relevant details as part of the report.

Good Faith

Reports of alleged prohibited conduct must be made in good faith. Reports that are not made in good faith may be a form of retaliation under this policy and/or may violate other university policies. All parties and witnesses have an obligation to be truthful in the process.

University’s Response

The Bias Incident Response Team receives all reports. The Vice President for Strategic Operations & Human Resources or their designee will take the lead on contacting the individual who made the report, performing the initial intake, and coordinating the process. The Vice President for Strategic Operations & Human Resources will explain the process, answer questions, and assist the individual in making contact with campus safety and security and other appropriate resources.

The Bias Incident Response Team, a group of trained university employees, will consider how to proceed with regard to the report. If this initial evaluation determines that the university should move forward with conduct procedures, the process will be initiated. In cases where it is determined that there is no policy violation, this group will discuss any other procedures, including a conversation with involved parties.

Investigations

Investigations will provide a fair and reliable gathering of the facts. Investigations will be thorough, impartial, fair, and will be adjudicated according to a standard of the preponderance of evidence to determine whether it is more likely than not a violation occurred.

Appeals

Either the complainant or respondent may appeal the results of the formal resolution process for one or more of the following reasons:

A procedural error occurred that substantially affected the outcome of the process.
There has been the discovery of significant new factual material that was not previously available to submit to the investigator that could have affected the original outcome.
- Intentional omission of factual information by the appealing party is not a ground for an appeal.
The sanction or other response by the university under the formal resolution process was excessively severe or grossly inadequate.

Either party may request an appeal by submitting a written appeal statement, not to exceed 2,000 words, which must explain which of the bases above the party is citing for the appeal. A written appeal must be submitted to the President’s Cabinet within seven (7) calendar days following the notification of findings. Failure to file a timely appeal constitutes a waiver of any right to an appeal.

In an appeal, the burden of proof is on the appealing party to show that it is more likely than not (i.e. preponderance of evidence) that one or more of the above grounds for appeal are satisfied.

Appeals are not allowed in cases where the parties have agreed to a voluntary alternative resolution of the matter.

Sanctions

In imposing any sanctions and remedies for a policy violation, the university reserves the right to take measures deemed necessary to protect the rights and personal safety of the complainant and the university community.

Retaliation

The university prohibits any form of retaliation against any individual because of the individual’s good faith participation in reporting or otherwise expressing opposition to, suspected or alleged misconduct, or participating in any process designed to review or investigate suspected or alleged misconduct or noncompliance with applicable policies, rules, and laws. No employee will be adversely affected because they refused to carry out a directive which constitutes fraud or is a violation of local, state, federal or other applicable laws and regulations.

Individuals who believe that retaliation is occurring or has occurred, as a result of their good faith participation, must report those acts to the Office of Human Resources or to the appropriate university administrator to which the complainant feels most comfortable reporting.

Reason for Policy

This policy provides information regarding the university’s prevention efforts related to bias, discrimination, and harassment. The policy also explains how the university will proceed once it is made aware of the allegations of prohibited conduct in keeping with the university’s values and in order to meet the legal obligations of Title VI, Title VII, and Title IX, and other applicable laws.

Policy Scope

This policy applies to all North Central University community members, including on campus and online students, employees, faculty, administrators, staff, applicants for admission, and to other individuals or entities, such as visitors, volunteers, vendors, consultants, third parties, or other individuals or entities that interact with any member of the university’s community, have any official capacity with the university, or are present on university property.

This policy applies to all forms of bias, discrimination, and harassment, except for sexual misconduct which encompasses sexual harassment, sexual assault, domestic violence, dating/intimate partner violence, stalking, and sexual exploitation. Concerns about sexual misconduct should be reported in accordance with the university’s Sexual Misconduct (Title IX) policy, which establishes separate procedures for reporting and resolving allegations of sexual misconduct. Allegations of sex discrimination that do not involve sexual misconduct will be processed under this policy.

Procedures

Reporting Bias, Discrimination, or Harassment

How to Report

Individuals are encouraged to make a report as soon as possible following an alleged incident. There is no statute of limitations for reporting prohibited conduct to the university under this policy; however, the university’s ability to respond may diminish over time, as evidence may erode, memories may fade, and respondents may no longer be affiliated with the university.

Reports of alleged bias, discrimination, or harassment, other than sexual misconduct, must be made via the university’s Bias Incident Form. Reports of sexual misconduct must be made, pursuant to the university’s Sexual Misconduct (Title IX) policy, to the university’s Title IX Coordinator.
- Reports can be made by telephone, email, in person, and/or on the university website.
- Individuals also have the option of making an anonymous report using the University’s website.
  - The university may be limited in its ability to investigate an anonymous report unless sufficient information is furnished to enable the university to conduct a meaningful and fair investigation. The individual making the report is encouraged to provide as much detailed information as possible to allow the university to investigate the report and respond as appropriate.
- For incidents involving an emergency situation where there exists an immediate threat of physical harm to any person or property or medical attention is required, community members should call 911 and Campus Safety & Emergency Preparedness at the following phone number: 612.343.4445. In addition, if you believe a crime has occurred, you may contact Campus Safety & Emergency Preparedness at the above number or the Minneapolis police at:
  - 911 (for emergencies)
  - 311 (for non-emergencies)
  - Minneapolis Police Department
    - 350 South 5th Street, Room 130
    - Minneapolis, MN 55415
  - Submit an online police report

Responding to Complaints of Bias, Discrimination, or Harassment

The Bias Incident Response Team (BIRT) will receive and review all reports of actual or suspected bias, discrimination, or harassment. A member of the BIRT or their designee will conduct an initial review and assessment of a complaint to determine the appropriate course of action and may exercise discretion to determine an appropriate responsive process based on the facts and circumstances. Options for resolution include, but are not limited to:

Informal Resolution: informal discussions and resolution facilitated by the BIRT.
Formal Resolution: investigation and determination by the BIRT, or assignment of a designated individual(s) to investigate the complaint and determine an appropriate response.
Dismissal: Following an initial review and evaluation of the complaint, the BIRT may conclude that no further investigation or action is warranted, because the allegations do not raise a potential violation. If the BIRT determines that the complaint, even if substantiated, would not be a violation of this policy, the BIRT has discretion to dismiss the matter or refer it to other applicable university disciplinary procedures. The parties will be notified of any such determination and of other resources that may be available to the complainant.

All parties will be notified of the determination regarding the appropriate course of action.

Interim Measures

When the university receives a report of alleged prohibited conduct, it will assess the allegations to determine whether interim measures pending resolution of the matter are appropriate.

The BIRT will work with the Vice President for Strategic Operations & Human Resources and appropriate academic administrators to initiate interim actions, accommodations, or protective measures as necessary to protect the parties and the broader university community. Such interim actions, accommodations, and protective measures are available to the complainant, respondent, and others adversely impacted by the complaint resolution process, if requested and reasonably available.
The university determines which measures are appropriate on a case-by-case basis. Such measures are based on the particular facts and circumstances of each case. To request an interim action or protective measure, individuals should contact the BIRT.

Informal Resolution Option

If the complainant, the respondent, and the university all agree to pursue an informal resolution, the BIRT or their designee will attempt to facilitate a resolution that is agreeable to all parties. Informal resolution may involve the imposition of sanctions on a respondent and individual and community remedies. Any informal resolution must adequately address the concerns of the complainant, as well as the rights of the respondent and the overall intent of the university to stop, remedy, and prevent policy violations.

The BIRT or their designee will not be an advocate for either the complainant or the respondent, but rather will aid in the resolution of problems in a non-adversarial manner.
Under the informal process, the university will only conduct such fact-finding as is useful to resolve the conflict and as is necessary to protect the interests of the parties, the university, and the university community.
The university will not compel a complainant or respondent to engage in mediation, to directly confront the other party, or to participate in any particular form of informal resolution.
Participation in informal resolution is voluntary, and the complainant and respondent have the option to discontinue the process at any time and request a formal process.
The university also always has the discretion to discontinue the informal process and move forward with a formal process.
If at any point during the informal resolution process, the complainant or respondent or the university wishes to cease the informal process and to proceed through the formal resolution process, the informal resolution process will stop and the formal resolution process outlined below will be invoked.

After informal Resolution

If the parties to the complaint agree in writing to the terms and conditions of a recommended resolution within any timeline set by the BIRT, the case will be resolved without further process under this policy.
If all parties to the complaint do not timely agree in writing to the terms and conditions of the recommended resolution, the complaint will be referred to the formal resolution process.
If the complaint is referred to the formal resolution process, the time spent attempting to reach an informal resolution generally will not be counted as part of the 60-day time frame discussed in the Formal Resolution Option section below.

Formal Resolution Option

Generally, the process described below will be used for the formal processing of a complaint of prohibited conduct. The university will strive to complete the complaint resolution process within 60 days. However, this time frame may be extended depending on the circumstances of each case.

Investigation

The Bias Incident Response Team will designate one or more investigators to investigate the complaint. The university reserves the discretion to appoint any investigator, including an outside investigator.

The investigator(s) will conduct the investigation in a manner appropriate to the circumstances of the case; investigations may include interviews with the complainant, the respondent, and appropriate witnesses, and gathering any relevant and available evidence.
The complainant and respondent will be given an opportunity to inform the investigator of any witnesses they believe should be interviewed, and other evidence they believe should be reviewed by the investigator(s).
The investigator(s) has discretion to assess the relevancy of the proposed witnesses and/or evidence and determine the scope of the investigation. Character evidence is generally irrelevant and will generally not be considered in an investigation.

Determination and Sanctions

The Bias Incident Response Team will adjudicate the complaint.

Following the investigation, the adjudicators will review the information gathered by the investigator(s).
The adjudicators will apply the preponderance of evidence standard to determine whether it is more likely than not that the respondent violated university policy.
If the adjudicators determine that the respondent is responsible for a policy violation, the adjudicators will then assign appropriate sanctions and remedies.
As part of assigning sanctions/remedies, the adjudicator(s) may request information from the university regarding any previous violations of this policy by the respondent and consider such other policy violations in assigning sanctions.

If an investigation reveals that a campus organization (such as a student club, athletic team, campus academic department, or staff/faculty committee) has committed or promoted behavior that violates this policy, the organization and its members may be sanctioned. All campus organizations/departments are responsible for the actions of its members when they are operating on behalf of the organization/department.

Notification of Findings

The complainant will be notified in writing of the decision and sanctions that directly relate to the complainant.

The university will communicate the decision to the parties in an appropriate notice.

The respondent will be notified in writing of the decision and sanctions.

Frequently Asked Questions

Q: What does this policy cover?

A: All forms of bias, discrimination, and harassment except sexual misconduct, which the Sexual Misconduct (Title IX) policy covers. Sex discrimination that does not involve sexual misconduct falls under this policy.

Q: How do I report an incident?

A: Submit the Bias Incident Form or tell a university employee. Report sexual misconduct to the Title IX Coordinator at titleix@northcentral.edu.

Q: Do employees have to report?

A: Yes. Employees must report actual or suspected incidents of bias, discrimination, or harassment as soon as possible. They must not investigate on their own.

Q: Can I report anonymously?

A: Yes, through the university website. An anonymous report may limit the university’s ability to investigate, so include as much detail as possible.

Q: Does a deadline apply to reports?

A: No. However, report as soon as possible, because evidence and memories fade over time and people may leave the university.

Q: Who reviews reports?

A: The Bias Incident Response Team (BIRT) receives and reviews all reports and decides how to proceed.

Q: How does NCU resolve a complaint?

A: The BIRT may pursue informal resolution, formal resolution through an investigation and determination, or dismissal when the allegations would not violate the policy. Informal resolution requires agreement from both parties and the university.

Q: How long does the formal process take?

A: The university strives to finish within 60 days, though complex cases may take longer.

Q: Can I appeal a decision?

A: Yes. Submit a written appeal of up to 2,000 words to the President’s Cabinet within seven calendar days of the notification of findings. Appeals must cite a procedural error, significant new information, or a sanction that seems excessively severe or grossly inadequate.

Q: What if someone retaliates against me for reporting?

A: The university prohibits retaliation. Report it to the Office of Human Resources or to the university administrator you feel most comfortable contacting.

Forms

Bias Incident Form

Appendices

There are no appendices associated with this policy.

Additional Contacts

Subject	Contact	Phone	Email
Primary Contact	Office of Human Resources	612.343.4412	hr@northcentral.edu
Title IX Coordinator	Office of Human Resources	612.343.4412	titleix@northcentral.edu
Student Conduct	Office of Student Development	612.343.4450	studlife@northcentral.edu
Emergencies		911
Campus Safety	Campus Safety & Emergency Preparedness	612.343.4445	security@northcentral.edu
Campus Safety – Emergencies	Campus Safety & Emergency Preparedness	612.343.4444

Definitions

Accused

An individual who has been accused of prohibited conduct under this policy.

Adjudicator

Trained, neutral, and impartial decision-maker.

Adverse Action

Any action that might deter a reasonable person from engaging in reporting suspected or alleged misconduct, expressing opposition to alleged misconduct, participating in an investigation related to a misconduct allegation, or accessing Office of Human Resources services. Examples of adverse action include, but are not limited to: impeding the individual’s academic advancement; departing from any customary academic or employment practice regarding the individual; firing, refusing to hire, or refusing to promote the individual; transferring or assigning the individual to a lesser position in terms of wages, hours, job classification, job security, employment or academic status; and threatening or marginalizing an individual. In some situations, retaliatory conduct may also include inappropriate disclosure of the identity of the individual who has made a complaint protected by this policy.

Bias

An act directed toward an individual or community based upon actual or perceived background or identity including: age, color, disability, gender identity or expression, marital status, national origin, race, religion, sex, sexual orientation, or veteran status.

Bias Incident Response Team

The Bias Incident Response Team is a trained group of university employees that receives incident reports, conducts investigations, and adjudicates incidents.

Complaint

An alleged policy violation that begins a complaint resolution process under this policy.

Complainant

The person(s) filing a complaint with the University under this policy. The term “complainant” may also be used to refer generally to a person alleged to have been subjected to conduct that violates this policy, whether or not the person has filed a complaint.

Discrimination

The differential treatment based on a person’s protected characteristic, including sex, race, color, national origin, age, religion, disability, marital or familial status, pregnancy, genetic information, veteran status, or any other legally protected characteristic, that interferes with or limits that person’s ability to participate in or benefit from a program or activity of the University or that adversely affects a term or condition of an individual’s employment or education.

Harassment

The unwelcome verbal or physical conduct based upon a person’s protected characteristic, including sex, race, color, national origin, age, religion, disability, marital or familial status, pregnancy, genetic information, veteran status, or any other legally protected characteristic when:

Submission to that conduct is made, either explicitly or implicitly, a term or condition of an individual’s educational experience or employment, or the individual’s submission or rejection of such conduct is used as the basis for an employment, academic, or other educational decision; or
Such conduct has the purpose or effect of substantially and unreasonably interfering with an individual’s employment or education, or of creating an intimidating, hostile, or offensive employment or educational environment (“hostile environment” harassment).

Hostile Environment

Includes any situation in which there is harassing conduct that is sufficiently severe, pervasive/persistent, and clearly/objectively offensive that it alters the conditions of education or employment, from both a subjective (the victim’s) and an objective (reasonable person’s) viewpoint.

The circumstances to determine whether an environment is “hostile” could include:

The frequency of the conduct.
The nature and severity of the conduct.
Whether the conduct was physically threatening.
The effect of the conduct on the victim’s mental or emotional state.
Whether the conduct was directed at more than one person.
Whether the conduct arose in the context of other discriminatory conduct.
Whether the conduct unreasonably interfered with the victim’s educational or work performance.
Whether the statement is an utterance of an epithet which engenders offense in an employee or student, or offends by rudeness.
Whether the speech or conduct deserves the protections of academic freedom.

Interim Measures

Examples of interim actions include, without limitation:

Establishing a “no contact” directive prohibiting the parties involved from communicating with each other during the response and resolution process.
Special parking arrangements.
Changing an individual’s campus residency, facility access, dining or transportation arrangements.
Changing an individual’s student or employee status or job responsibilities.
Changing an individual’s work or class schedule or job assignment.
Providing academic accommodations or providing assistance with academic issues.
Arranging a leave of absence.
Providing security escorts.
Assisting with the identification of support resources, such as counseling and medical services

Preponderance of Evidence

Preponderance of the evidence means that it is more likely than not that a policy violation has occurred.

Reasonable Person

A reasonable person under similar circumstances and with similar identities to the complainant.

Report

An account of the conduct that has allegedly occurred in violation of this policy.

Respondent

The person(s) named as the accused in a complaint under this policy.

Retaliation

Adverse action against an individual because the individual has made a protected disclosure or has participated in an investigation, proceeding or hearing involving a protected disclosure.

Sanctions

Consequences of policy violations.

Sanctions for employees may include, but are not limited to: education, training, counseling, coaching, warnings, reprimands, transfer, demotion, loss of compensation, privilege and/or access restrictions, no contact and/or no trespass directives, restitution, behavioral agreements, termination of employment, and/or ineligibility for rehire.

Sanctions for students may include, but are not limited to: education, training, counseling, coaching, warnings, reprimands, privilege and/or access restrictions, no contact and/or no trespass directives, restitution, behavioral agreements, delay of a diploma or degree, denial of a diploma or degree, revocation of a diploma or degree, probation, suspension, expulsion, and/or ineligibility for re-admission.

Sanctions to university organizations may include, but are not limited to, loss of university privileges (including, but not limited to, prohibition on the organization’s participation in certain activities and the use of university facilities), educational requirements for organization members, required additional oversight of organization activities, temporary loss of funding and/or loss of recognition by the university, and permanent loss of organization recognition, in addition to individual members of the organization who are determined responsible for a policy violation being subject to the sanctions listed above.

University Community Member

On-campus and online students, employees, faculty, administrators, staff, applicants for admission, and to other individuals or entities, such as visitors, volunteers, vendors, consultants, third parties, or other individuals or entities that interact with any member of the university’s community, have any official capacity with the university, or are present on university property.

Responsibilities

University Community Members

Report instances of discrimination and harassment.
Participate in investigations related to discrimination and harassment.

Office of Human Resources

Receive complaints related to instances of discrimination and harassment.

Vice President for Strategic Operations & Human Resources

Manage the procedures related to this policy.
Coordinate investigations related to instances of discrimination and harassment.

Adjudicators

Review evidence related to claims of discrimination.
Impose sanctions and/or remedies as necessary to end the misconduct, prevent its recurrence, and address its effects.

University President

Receive, as necessary and appropriate, complaints related to instances of discrimination and harassment by the Office of Human Resources.
When required, coordinate investigations related to instances of discrimination and harassment.

Chair, Board of Regents

Receive, as necessary and appropriate, complaints related to instances of discrimination and harassment.
When required, coordinate investigations related to instances of discrimination and harassment.

Related Policies & Procedures

Related Legislation

Title VI and Title VII of the Civil Rights Act of 1964
Title IX of the Education Amendments of 1972
Age Discrimination in Employment Act
Americans with Disabilities Act as amended
Minnesota Human Rights Act

History

Amended

2026-10-01 – Non-substantive updates (e.g., titles, contacts, link corrections, and copy errors); removed individual team member names; moved procedures onto the policy page; added frequently asked questions.

2021-08-25 – Updated reporting form. Updated members of Bias Incident Response Team.

2020-08-10 – Updated members of Bias Incident Response Team.

Issued

2020-02-18

← Administration & Operations Policies

All Policies

Admissions

Visit Our Campus

Life at NCU

Visit Our Campus

About

Giving at NCU