Introduction
Pacific Lutheran University’s Office of Diversity, Justice, & Sustainability is dedicated to upholding PLU’s commitment to being a diverse, equitable, and inclusive community where all students, faculty, and staff can thrive.
In alignment with state and federal laws—including Title VI, Title VII, Title IX, the ADA, and other civil rights legislation—our office works to mitigate and respond to prohibited conduct, including discrimination and harassment based on race, color, national origin, shared ancestry and ethnicity, and limited English proficiency in all University programs and activities, including employment, education, and student services.
What is Title VI and Title VII
Title VI and Title VII and its corresponding regulations require Pacific Lutheran University, as an institution receiving federal funding for student financial aid, to provide a living and learning environment that is free from discrimination or harassment based on race, color, or national origin. In coordination with the Civil Rights Act, PLU policies strictly prohibit discrimination, harassment, and retaliation, intentional or unintentional, based on race, color, and national origin in all University programs and activities, including academics, employment, and housing.
At PLU, upholding Title VI and Title VII is a core part of our commitment to care and to the dignity and value of every individual in our community.
Scope of Protection
The protections under Title VI and Title VII are broad and extend to a person’s actual or perceived characteristics, including:
- Race, Color, and National Origin: Skin color, complexion, and where a person or their ancestors originate from
- Shared Ancestry and Ethnicity: Including ethnic characteristics or ancestry (e.g., specific ethnic groups)
- Limited English Proficiency
Title VI and Title VII and Religious Discrimination
Title VI and Title VII protections also extend to individuals of any religion when discrimination or harassment, intentional or unintentional, is based on characteristics that overlap with national origin or ancestry. This includes discrimination based on:
- Shared Ancestry or Ethnic Characteristics (e.g., targeting individuals who are perceived to be of a particular national origin or shared ancestry, such as Hindu, Jewish, Muslim, or Sikh individuals)
- Citizenship or Residency in a country with a dominant religion or distinct religious identity
Examples of Prohibited Conduct
Conduct that is based on an individual’s protected characteristic and is so severe or pervasive that it creates a hostile environment may violate Title VI, Title VII, and PLU policies.
In order to meet the standard for a hostile environment under Title VI and VII, conduct must be evaluated using and including evidence from all three of the following metrics:
- The totality of the circumstances;
- Be subjectively and objectively offensive;
- Be severe and pervasive.
And, as a result of meeting these three conditions, limit or deny a person’s ability to participate in or benefit from a program or activity.
Filing a Complaint
The Title VI and Title VII Coordinator in the Office of DJS is responsible for
- Receiving and processing official Title VI and Title VII reports
- Managing Title VI and Title VII investigations
- Providing opportunities for compliance training for all members of the PLU community
- Coordinating and consulting with various constituents to provide remedies to mitigate harm and to address impact, including at the time of report and during an investigative process.
Process
With the receipt of the formal report, PLU initiates a timely and comprehensive investigation into the report. Whenever feasible, reports are acted on within 24 hours, unless a situation compels a more rapid response. Participants in a process should expect the following:
- Provide timely communication outlining the process to all named parties
- Provide immediate, interim supportive measures to mitigate harm and impact to all named parties
- Schedule interviews to gather information
- Comprehensive interviews with all named parties
- Draft summaries, final report, and rationale for determination within 10 business days of the reported incident, or sooner if compelled by safety concerns.
- Communicate determination based on assessment of evidence available and gathered during the investigation and provide documentation of the determination to all parties involved in the complaint
- If a violation has occurred, a determinations will be made using the clear and convincing standard of evidence and appropriate remedies, resolutions, and/or sanctions will be assigned
- If conditions do not meet the standards for a Title VI or VII violation, alternative remedies, including, care for parties impact, mediation, additional consultation, or referral to Student Rights & Responsibilities if student code of conduct or employee personnel policies, may be relevant and can still be recommended for follow-up may be assigned
- Participants in a Title VI or VII case may appeal a report after a determination has been communicated and based on at least one of the following concerns:
- Severity of sanction
- Newly available evidence that could not have been reasonably made available during the investigation
- Documentable bias in Title VI or VII procedures
- Title VI appeals involving students should be submitted to the Vice President for Student Life within 5-days of receiving the case determination letter
- Title VII appeals involving employees or students and employees should be submitted to the Vice President for Administrative Services within 5-days of receiving the case determination letter
