Many new Title IX coordinators receive little guidance when starting their roles. Training is available but much of it pertains to the interpretation of the law instead of explaining how to do the job. The first part of this series, “What to Look for in a Title IX Coordinator for Your K-12 Campus,” helped frame the role. This part addresses key first steps in creating a place and a forum for Title IX in your district.

The Title IX coordinator is a federally mandated position. A person hired for this role must have institutional support. An important message is that if you can do your job with full cooperation, you will help keep the school district out of the courts.

A fundamental working condition should be that you have full access and communication with the superintendent’s office. You should know about any policy or changes that involve the protections afforded under Title IX — hopefully before final decisions are made. These can include hiring practices and building renovations. For example, I dealt with one middle school that renovated the entire school but neglected to update the girls’ locker room. Imagine touring the spacious boys’ locker rooms with gleaming new lockers, sinks and showers, and then seeing the girls’ facilities, built in the 1950s, with splintering wooden benches and showers used as storage space.

Unless you went to law school and have been schooled specifically in Title IX and other civil rights laws, there will be issues that are “above your pay grade.” You should have ready access to your school attorney for legal advice. If in doubt, consult with the school lawyer. If your school gets sued, it will be your school attorney who has to defend the district in court.

If a school employee gets charged with any kind of sexual misconduct will you, as the Title IX coordinator, be kept in the loop? Do you have an open working relationship with the human resources department? Do they understand that educators are covered under Title IX as well as Title VII?

Title VII is an employment law that protects employees against discrimination based on certain specified characteristics such as race, color, national origin, sex, and religion. In cases where school employees are charged with sex discrimination, HR should take the lead because union agreements often apply. In some situations, an alleged Title VII violation might not hold but a Title IX complaint might. Take the example of a school principal who ignores a sexual harassment complaint by a teacher. They could possibly avoid punishment for sex discrimination under Title VII but still be liable under Title IX for failure to follow the required complaint procedure. Again, this is where consultation with the school attorney is advisable.

If you investigate a sex discrimination complaint that involves students of color, Title VI might apply. Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs or activities receiving federal financial assistance. Find out who handles Title VI violations in your district. Does that person understand that violations under Title VI may also constitute Title IX violations? Most school districts now have a person who leads anti-bullying efforts. Bullying violations may also be Title IX violations. Coordinate with any other school individual who has oversight responsibilities for civil rights protections.

Make an appearance at a school board meeting so the members get to know you. While at the meeting, introduce yourself to people, especially those that represent interested groups, such as the PTO/PTA and civil rights advocacy groups. Follow the agendas and read the minutes watching for issues that might be of concern.

Here are some other connections you should make:

• Head of Guidance Department: To review data on participation in Career Technical Education courses by sex and create a remediation plan if needed.
• Athletic Director: To review data on participation in athletics by sex and create a remediation plan if needed.
• Head of Maintenance/Facilities Director: To monitor equity in facilities. Common violations are lack of comparable athletic fields, snack bars, field houses, and more.
• PTO/PTA: Make occasional appearances to maintain a relationship and to educate parents and guardians.
• Union Leaders: They are required to be informed about Title IX.
• School Resource Officers (SROs) and Security Guards: This is an important relationship to maintain to ensure protections under Title IX.
• Publication: If you have a person in charge of publishing school material, make sure they understand the requirement to include the district’s nondiscrimination statement in all publications.
• Information Technology: The website should be transparent and easily accessible for information on Title IX. The nondiscrimination statement with your contact information should ideally be on the main page in the footer, at least. Test the web search box to make sure searches for topics like sexual harassment, sexual assault, complaint procedure, and Title IX all lead to a main source where information is located.

You should form working relationships with the local police department, especially SROs or Youth Bureau Officers. Consider creating a Memorandum of Agreement (MOA) with the police department on how to handle Title IX cases that might also be criminal violations.

State Civil Rights Agencies are helpful resources. All 50 states, including the District of Columbia, have a civil rights agency or government division. The Anti-Defamation League (ADL) provides excellent programs for students. They have 25 regional offices in the United States. I have found the American Civil Liberties Union (ACLU) helpful, especially in First Amendment issues.

The key to working with external agencies is to NOT think of them as the enemy but as a partner in helping address complaints. I will discuss working with the U.S. Office for Civil Rights in the next article.

Finally, religious and cultural organizations can be key allies when working with youth in their communities because students often speak to their community cultural leaders before they reach out to school officials. I conducted several presentations at mosques for parents and their children, especially after anti-Muslim incidents. These were conducted with attorneys from the state civil rights agency, and sometimes with attorneys from the Department of Justice/U.S. Attorney’s Office.

I cannot emphasize enough the value of making personal connections. I have found the leader of the Muslim communities, the Imam, to be most helpful in explaining culture and tradition. In the Sikh faith, the holy places of worship are called a gurdwara. They are under the leadership of a trained leader or any qualified adult. And of course, the Jewish community has, unfortunately, had to deal with centuries of discrimination and persecution. The rabbis I have worked with actually enjoy having my future teachers attend services to learn more about the faith and the culture.

You can send out all the letters, postcards and emails you want to cultural organizations but the most effective way I have found to make connections is to show up at their events. For example, I have been to numerous Chinese, Laotian, Cambodian, and Nepali New Year’s events where hundreds of people are in attendance. Colleagues have attended Korean Baptist church services and picnics where the venues are filled. Greek and Italian festivals are fun, and you will often run into politicians and local celebrities. I have made many important connections at these events. In many cultures, person-to-person contact is significant. Contacts like these open up helpful connections for being made aware of concerns and learning about cultural influences. And the food and entertainment are amazing.

Being a Title IX Coordinator, often in addition to other duties, can be a daunting task, but you don’t have to work alone. Seek out allies who will support your work.

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Dr. Bill Howe was the Connecticut State Title IX Coordinator for 17 years. 

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