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Title IX & Sexual Harassment

Notice of Nondiscrimination

Calvary Chapel Bible College (“CCBC” or “the College”) prohibits discrimination on the basis of sex, including sexual harassment, sexual assault, dating violence, domestic violence, stalking, and retaliation, as described in this policy.

This prohibition applies to students, applicants for admission, employees, applicants for employment, and other persons participating or attempting to participate in a College education program or activity.

CCBC is a religious educational institution. The College reserves all rights and exemptions available to it under applicable law when compliance would conflict with the religious tenets of the College or its controlling religious organization.

Questions regarding this policy or Title IX may be directed to CCBC’s Title IX Coordinator, the Deputy Title IX Coordinator, or the U.S. Department of Education’s Office for Civil Rights.

Get Help or Report a Concern

Any person may report sex discrimination, sexual harassment, retaliation, or related misconduct, whether or not the person making the report is the person alleged to have experienced the conduct.

Reports may be made in person, by telephone, by email, or by mail. Reports may be made at any time, including outside regular business hours.

Title IX Coordinator

Ana Little
Business Administrator
Calvary Chapel Bible College
4200 32nd St. W., Unit A
Bradenton, FL 34205
Email: alittle@ccbc.info
Telephone: (941) 241-4075

Deputy Title IX Coordinator and Alternate Contact

Pilgrim Benham
Dean of Students
Calvary Chapel Bible College
4200 32nd St. W., Unit A
Bradenton, FL 34205
Email: pbenham@ccbc.info
Telephone: (941) 241-3141

A person may contact the Deputy Title IX Coordinator directly if the Title IX Coordinator is unavailable, if the report concerns the Title IX Coordinator, or if the person would otherwise prefer to contact the alternate.

If a report concerns the Deputy Title IX Coordinator, it should be made to the Title IX Coordinator.

If a report concerns both the Title IX Coordinator and Deputy Title IX Coordinator, it may be made to the President by calling the College’s main telephone number at (941) 900-3880. The caller should request that the matter be directed confidentially to the President.

If a report concerns the President, it may be made to the Chair of the Board of Trustees through the College’s main telephone number at (941) 900-3880. The caller should request that the matter be directed confidentially to the Chair of the Board of Trustees.

Emergencies and Reports Involving Minors

Anyone facing an immediate threat or emergency should call 911.

A person may also report conduct that may constitute a crime directly to local law enforcement. Reporting to law enforcement and reporting to CCBC are separate options, and a person may pursue either or both.

Suspected abuse, abandonment, or neglect of a minor should be reported immediately to the appropriate law-enforcement agency and the Florida Abuse Hotline at 1-800-962-2873, as required by Florida law. Reporting suspected abuse to CCBC does not replace any legal obligation to make an external report.

What Happens After a Report

After receiving a report, the Title IX Coordinator or designee will promptly contact the person alleged to have experienced the conduct to:

  • discuss the availability of supportive measures;
  • consider that person’s wishes regarding supportive measures;
  • explain the process for filing a formal complaint;
  • discuss available College and community resources;
  • consider immediate safety concerns; and
  • explain the options available under this policy.

Submitting a report does not necessarily require the affected person to file a formal complaint or participate in a disciplinary process. In some circumstances, however, the Title IX Coordinator may determine that the College must take additional action to protect an individual or the College community.

Supportive Measures

Supportive measures are individualized, non-disciplinary, and non-punitive services offered as reasonably appropriate and available. They are designed to restore or preserve access to the College’s education programs and activities, protect the safety of the parties or the College community, or deter prohibited conduct.

Supportive measures may include:

  • academic support or adjustments;
  • changes to class schedules or campus activities;
  • changes to housing assignments;
  • changes to work assignments or schedules;
  • mutual restrictions on contact;
  • increased security or monitoring;
  • campus safety assistance;
  • referrals to counseling, medical, pastoral, or community resources;
  • assistance contacting law enforcement; and
  • other measures appropriate to the circumstances.

Supportive measures may be offered before or after a formal complaint is filed and may be offered even when no formal complaint is filed.

The College will maintain the privacy of supportive measures to the extent doing so does not impair its ability to provide them.

Scope of This Policy

This policy applies to conduct occurring in a CCBC education program or activity within the United States. This includes locations, events, or circumstances over which the College exercises substantial control over both the person accused of the conduct and the context in which it occurs. It may include conduct occurring:

  • on College property;
  • in College housing;
  • during College classes, programs, ministries, trips, or activities;
  • through College-controlled online systems or learning environments; or
  • in buildings owned or controlled by an officially recognized student organization, if applicable.

Conduct that does not fall within the jurisdiction required for a formal Title IX grievance process may still violate other College policies. CCBC may address such conduct under its student conduct, employee, harassment, discrimination, or other applicable procedures.

Nothing in this policy prevents CCBC from providing supportive measures or addressing safety concerns merely because alleged conduct falls outside the formal jurisdiction of Title IX.

Prohibited Conduct

Sex Discrimination

Sex discrimination means treating a person differently or denying a person access to an education program, activity, employment opportunity, benefit, or service on the basis of sex, subject to any applicable religious or legal exemption.

Sexual Harassment

For purposes of the formal Title IX grievance process, sexual harassment means conduct on the basis of sex that satisfies one or more of the following:

  1. Quid pro quo harassment: A College employee conditions the provision of a College aid, benefit, or service on a person’s participation in unwelcome sexual conduct.
  2. Hostile-environment harassment: Unwelcome conduct that a reasonable person would determine is so severe, pervasive, and objectively offensive that it effectively denies a person equal access to a College education program or activity.
  3. Sexual assault, dating violence, domestic violence, or stalking: Conduct meeting the applicable definitions of these offenses under federal law.

Conduct that does not meet the federal definition of Title IX sexual harassment may nevertheless be prohibited and addressed under other College policies.

Sexual Assault

Sexual assault includes any sexual act directed against another person without that person’s consent, including circumstances in which the person is incapable of giving consent, as defined by applicable federal law.

Dating Violence

Dating violence means violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the affected person. The existence of such a relationship is considered based on its length, type, and frequency of interaction.

Domestic Violence

Domestic violence includes felony or misdemeanor crimes of violence committed by a current or former spouse or intimate partner, a person with whom the affected person shares a child, a person who is cohabitating or has cohabitated as a spouse or intimate partner, or another person covered by applicable domestic-violence law.

Stalking

Stalking means engaging in a course of conduct directed at a particular person that would cause a reasonable person to fear for personal safety or the safety of others or to suffer substantial emotional distress.

Retaliation

Retaliation means intimidation, threats, coercion, discrimination, or other adverse action taken against a person because that person:

  • made a report or formal complaint;
  • requested supportive measures;
  • assisted or participated in an investigation, hearing, or resolution process;
  • declined to participate in a process; or
  • exercised a right protected by this policy or applicable law.

The prohibition against retaliation does not prevent the College from addressing knowingly false statements or other misconduct established through an appropriate process. A determination that a person was not responsible for alleged conduct does not, by itself, establish that the report was knowingly false.

Consent

Consent is an informed, voluntary, and mutual agreement to participate in sexual activity.

Consent:

  • must be freely and affirmatively communicated;
  • may be withdrawn at any time;
  • cannot be inferred solely from silence, passivity, or the absence of resistance;
  • cannot be inferred solely from a current or previous dating or sexual relationship;
  • must exist for each form of sexual activity; and
  • cannot be given by a person who is incapacitated, unconscious, asleep, coerced, or otherwise legally unable to consent.

The use of force, threats, intimidation, coercion, or abuse of authority is inconsistent with consent.

Privacy and Confidentiality

CCBC will make reasonable efforts to protect the privacy of persons involved in a report or resolution process. Information will ordinarily be shared only with persons who need it to carry out the College’s responsibilities, provide supportive measures, conduct a fair process, protect safety, or comply with law.

Privacy is not the same as legally protected confidentiality. Because CCBC is a small institution and does not designate its employees as confidential Title IX resources, employees who receive information about possible sexual harassment or sex discrimination should promptly share that information with the Title IX Coordinator.

The College cannot promise complete confidentiality when doing so would prevent it from responding appropriately or fulfilling a legal obligation.

A person may discuss available reporting options with the Title IX Coordinator without necessarily filing a formal complaint.

Formal Complaints

A formal complaint is a written or electronic document filed by a complainant, or signed by the Title IX Coordinator, alleging sexual harassment against a respondent and requesting that the College investigate.

A formal complaint may be submitted in person, by mail, or by email using the Title IX Coordinator’s contact information on this page. It must contain the complainant’s physical or electronic signature or otherwise indicate that the complainant is the person filing it.

At the time a formal complaint is filed, the complainant must be participating in or attempting to participate in a CCBC education program or activity.

The Title IX Coordinator may sign a formal complaint when an investigation is necessary even if the complainant does not wish to proceed. In making that decision, the Coordinator will consider the complainant’s wishes, the seriousness and circumstances of the allegations, potential threats to the College community, and the College’s obligation to respond appropriately. Signing a formal complaint does not make the Coordinator a complainant or a party.

Presumption of Non-Responsibility

A respondent is presumed not responsible for the alleged conduct unless and until responsibility is established through the applicable resolution process.

The filing of a report or formal complaint is not, by itself, evidence that prohibited conduct occurred.

Notice of Allegations

After receiving a formal complaint, the College will provide written notice to the known parties. The notice will include:

  • a description of the College’s grievance process;
  • sufficient details of the allegations known at the time;
  • the identities of the parties involved, if known;
  • the conduct allegedly constituting sexual harassment;
  • the date and location of the alleged conduct, if known;
  • a statement that the respondent is presumed not responsible;
  • a statement that responsibility will be determined at the conclusion of the process;
  • notice of each party’s right to an advisor of the party’s choice, who may be an attorney but is not required to be; and
  • notice that knowingly providing false information may violate College policy.

If additional allegations are investigated, the College will provide supplemental notice as appropriate.

Informal Resolution

After a formal complaint has been filed, the College may offer an informal resolution process when appropriate and permitted by law.

Informal resolution:

  • is voluntary;
  • requires written consent from all parties;
  • requires the College to provide written notice of the allegations and the nature and possible consequences of the process;
  • may be ended by either party before an agreement is reached, at which time the formal grievance process may resume; and
  • will be facilitated by a trained and impartial person.

Informal resolution will not be used to resolve allegations that a College employee sexually harassed a student.

Possible informal outcomes may include agreed supportive measures, educational requirements, restrictions on contact, changes in assignments or participation, or other voluntary terms.

Once an informal resolution agreement is finalized, its terms are binding unless the agreement itself provides otherwise.

Formal Grievance Process

Impartiality and Conflicts of Interest

The Title IX Coordinator, investigator, decision-maker, appeal decision-maker, and informal-resolution facilitator must serve impartially and without a conflict of interest or bias for or against complainants or respondents generally or any individual party.

A person assigned to one of these roles must disclose any actual or reasonably perceived conflict. The College may appoint a qualified outside professional when necessary to ensure impartiality or provide specialized expertise.

The investigator and decision-maker will not be the same person. The Title IX Coordinator will not serve as the decision-maker.

Investigation

The College will conduct a reasonably prompt, thorough, and impartial investigation.

The College—not either party—has the burden of gathering sufficient evidence and proving responsibility under the applicable standard of evidence.

During the investigation:

  • each party may identify witnesses and submit relevant evidence;
  • each party may be accompanied by an advisor of the party’s choice at meetings and proceedings;
  • the College will not restrict either party from discussing the allegations or gathering and presenting relevant evidence;
  • the parties will receive written notice of investigative meetings with sufficient time to prepare;
  • investigators will objectively evaluate relevant inculpatory and exculpatory evidence;
  • credibility will not be determined based on a person’s status as a complainant, respondent, or witness;
  • legally privileged information will not be used without an appropriate waiver; and
  • medical, psychological, or similar treatment records will not be accessed or used without the person’s voluntary written consent.

Before completing the investigative report, the College will provide both parties and their advisors, if any, an equal opportunity to inspect and review evidence directly related to the allegations.

The parties will have at least 10 calendar days to submit a written response to that evidence. The investigator will consider timely responses before completing the report.

The College will then provide the parties and their advisors with an investigative report that fairly summarizes the relevant evidence. The report will ordinarily be provided at least 10 calendar days before the hearing.

Live Hearing

For formal complaints governed by the federal Title IX grievance requirements for postsecondary institutions, CCBC will conduct a live hearing before a trained and impartial decision-maker.

At the hearing:

  • the parties may be located in separate rooms, with technology allowing them to see and hear one another;
  • the decision-maker will permit relevant questions and follow-up questions;
  • questions challenging credibility may be asked;
  • cross-examination will be conducted by each party’s advisor and never personally by a party;
  • the decision-maker will determine whether a question is relevant before an answer is given;
  • questions about a complainant’s prior sexual behavior or predisposition are generally not relevant, subject to limited exceptions required by law; and
  • the College will create an audio, audiovisual, or written transcript of the hearing and make it available to the parties for inspection and review.

If a party does not have an advisor for the hearing, the College will provide an advisor without charge for the limited purpose of conducting cross-examination. The College-appointed advisor may, but is not required to be, an attorney.

The decision-maker may consider relevant statements and evidence to the extent permitted under the currently applicable Title IX regulations and controlling law.

Standard of Evidence

CCBC uses the preponderance of the evidence standard. Under this standard, responsibility is established when the evidence shows that it is more likely than not that the alleged conduct occurred.

The same standard will be applied regardless of whether the respondent is a student or employee.

Written Determination

After the hearing, the decision-maker will issue a written determination simultaneously to both parties.

The determination will include:

  • identification of the allegations;
  • a description of the procedural steps taken;
  • findings of fact;
  • conclusions regarding the application of College policy;
  • the result for each allegation and the reasons for that result;
  • any disciplinary sanctions imposed on the respondent;
  • whether remedies designed to restore or preserve the complainant’s access to the College’s programs or activities will be provided; and
  • the procedures and permitted grounds for appeal.

The Title IX Coordinator is responsible for implementing any remedies.

Dismissal of a Formal Complaint

The College must dismiss an allegation from the federal Title IX grievance process when the alleged conduct, even if proved:

  • would not constitute Title IX sexual harassment as defined by the applicable federal regulations;
  • did not occur in a College education program or activity; or
  • did not occur against a person in the United States.

Such a dismissal does not prevent CCBC from addressing the conduct under another College policy or procedure.

The College may dismiss a formal complaint or allegation if:

  • the complainant provides written notice that the complainant wishes to withdraw it;
  • the respondent is no longer enrolled at or employed by CCBC; or
  • specific circumstances prevent the College from gathering evidence sufficient to reach a determination.

The College will provide the parties with written notice of a dismissal and the reasons for it. A dismissal may be appealed as provided below.

Emergency Removal and Administrative Leave

CCBC may remove a respondent from an education program or activity on an emergency basis when the College conducts an individualized safety and risk analysis and determines that an immediate threat to the physical health or safety of a person arising from the allegations justifies removal.

The respondent will receive notice and an opportunity to challenge an emergency removal promptly after it occurs.

The College may place an employee respondent on administrative leave while a grievance process is pending, consistent with applicable law and College policy.

Emergency action and administrative leave are not determinations of responsibility.

Possible Sanctions and Remedies

Sanctions will be determined according to the nature and severity of the conduct, relevant circumstances, prior disciplinary history when appropriate, and the need to protect the College community.

Possible sanctions for students may include, but are not limited to:

  • warning or reprimand;
  • educational requirements;
  • restrictions on contact or participation;
  • loss of privileges;
  • housing reassignment or removal;
  • disciplinary probation;
  • suspension;
  • dismissal or expulsion; and
  • other appropriate, immediate, escalated, or remedial action.

Possible sanctions for employees may include, but are not limited to:

  • warning or corrective action;
  • required education or training;
  • changes in duties or supervision;
  • restrictions on contact or access;
  • suspension;
  • termination of employment; and
  • other appropriate, immediate, escalated, or remedial action.

For visitors, contractors, or other third parties, consequences may include restrictions on access, removal from College property or activities, termination of a contractual relationship, or referral to law enforcement.

Remedies for a complainant may include supportive measures and other actions designed to restore or preserve equal access to the College’s education programs and activities. Remedies may be disciplinary or burdensome to the respondent after a finding of responsibility.

Appeals

Either party may appeal:

  • a determination regarding responsibility; or
  • the dismissal of a formal complaint or any allegation within it.

An appeal must be submitted in writing to the Title IX Coordinator within five business days after the written determination or dismissal is issued.

An appeal may be based on one or more of the following grounds:

  1. A procedural irregularity that affected the outcome.
  2. New evidence that was not reasonably available when the determination or dismissal was made and that could affect the outcome.
  3. A conflict of interest or bias by the Title IX Coordinator, investigator, or decision-maker that affected the outcome.
  4. Another substantial basis recognized by the College when fairness or applicable law requires review.

The College will notify the other party when an appeal is filed and provide both parties an equal opportunity to submit a written statement.

The appeal will be decided by a trained and impartial person who did not serve as the investigator, Title IX Coordinator, or original decision-maker. The appeal decision-maker will issue a written decision describing the result and rationale and will provide it simultaneously to both parties.

The appeal determination is final under this policy.

Timeframes

CCBC will make reasonable efforts to complete the formal grievance process, including investigation and determination, within 90 calendar days after the formal complaint is filed.

An appeal will ordinarily be resolved within 20 calendar days after the appeal period closes.

These timeframes may be extended temporarily for good cause. Good cause may include:

  • the complexity or scope of the allegations;
  • the absence or unavailability of a party, advisor, witness, or decision-maker;
  • concurrent law-enforcement activity;
  • the need for language assistance or disability accommodations;
  • College breaks or closures;
  • requests reasonably intended to facilitate participation;
  • safety concerns; or
  • other circumstances that reasonably require additional time.

The College will provide the parties written notice of a material delay or extension and the reason for it.

Advisors

Each party may select an advisor of the party’s choice. The advisor may be, but is not required to be, an attorney.

Except when conducting cross-examination at a live hearing, an advisor’s participation may be reasonably limited so that meetings and proceedings remain orderly and efficient. Restrictions will be applied equally to both parties.

The College does not pay the cost of a party’s chosen advisor. If a party does not have an advisor for a live hearing, the College will provide an advisor without charge for the limited purpose of conducting cross-examination.

Requests for Accommodations

A person who needs a disability-related accommodation or language assistance to participate in a process under this policy should contact the Title IX Coordinator. CCBC will consider reasonable requests consistent with applicable law and the need to maintain a fair process.

Employee Reporting Responsibilities

CCBC employees who receive information suggesting that sex discrimination, sexual harassment, sexual assault, dating violence, domestic violence, stalking, or retaliation may have occurred must promptly share that information with the Title IX Coordinator.

Employees should not promise confidentiality. Information should be limited to those who need it to respond appropriately.

An employee’s obligation to report information to the Title IX Coordinator does not necessarily mean that a formal complaint will be filed or that disciplinary proceedings will begin.

False Information and Interference

Knowingly making a materially false statement, submitting fabricated evidence, destroying relevant evidence, intimidating a participant, or intentionally interfering with a resolution process may result in disciplinary action.

A report made in good faith is not considered false merely because the evidence is insufficient to establish responsibility or because the reported conduct is ultimately found not to violate this policy.

Training

The Title IX Coordinator, Deputy Title IX Coordinator, investigators, decision-makers, appeal decision-makers, informal-resolution facilitators, and any other persons responsible for implementing this policy will receive training appropriate to their roles.

Training will address, as applicable:

  • the definition and scope of Title IX sexual harassment;
  • the College’s education programs and activities;
  • conducting impartial investigations and hearings;
  • relevance and evidentiary issues;
  • avoiding prejudgment, conflicts of interest, and bias;
  • supportive measures;
  • informal resolution;
  • technology used for live hearings; and
  • preparation of investigative reports and written determinations.

Training materials used to train Title IX personnel will not rely on sex stereotypes and will promote impartial investigations and resolutions. Materials required to be publicly available under applicable law will be posted or linked on this webpage.

Recordkeeping

CCBC will maintain records required by applicable law, including records of:

  • reports and formal complaints;
  • investigations;
  • hearing recordings or transcripts;
  • evidence and investigative reports;
  • written determinations;
  • disciplinary sanctions and remedies;
  • appeals and appeal decisions;
  • informal resolutions;
  • supportive measures;
  • the College’s response when no supportive measures are provided; and
  • training materials used for Title IX personnel.

Title IX records will generally be retained for at least seven years, or longer when required by another applicable law or College record-retention requirement.

Access to records will be limited to authorized individuals. Records will be maintained in the College’s designated institutional systems.

Relationship to Other College Policies

Conduct may violate more than one College policy. When conduct falls outside the required federal Title IX grievance process, CCBC may address it through another applicable student, employee, discrimination, harassment, conduct, safety, or grievance procedure.

The College may consolidate related allegations or coordinate related procedures when appropriate, provided doing so does not materially impair the rights provided under this policy.

Nothing in this policy limits a person’s right to make a report to law enforcement, pursue an external complaint, seek legal advice, or exercise another right provided by law.

Religious Character and Applicable Exemptions

CCBC is a Christian religious educational institution. Nothing in this policy should be interpreted to waive any religious exemption, constitutional protection, or other right available to the College.

When application of a legal requirement would conflict with the College’s religious tenets, beliefs, practices, or institutional religious mission, CCBC reserves the right to invoke any exemption or protection available under applicable law.

The College’s assertion of a religious exemption does not prevent it from maintaining institutional standards that prohibit sexual harassment, sexual assault, dating violence, domestic violence, stalking, retaliation, and other harmful misconduct.

External Complaints and Assistance

A person may contact the U.S. Department of Education’s Office for Civil Rights regarding questions about Title IX or to file a complaint of sex discrimination or retaliation.

U.S. Department of Education
Office for Civil Rights
400 Maryland Avenue, SW
Washington, DC 20202-1100
Telephone: 1-800-421-3481
TDD: 1-800-877-8339
Email: OCR@ed.gov

Online complaint information:
https://www.ed.gov/laws-and-policy/civil-rights-laws/file-complaint

A person is not required to complete CCBC’s internal process before contacting the Office for Civil Rights or another government agency.

Policy Administration

Questions about this policy should be directed to the Title IX Coordinator.

Effective Date: 08/01/2026
Last Revised: 08/01/2025