RCDS Complaints Management Policy

The Policy applies to a broad range of conduct and issues concerning the School, its students, staff, and contractors, vendors, or other non-employees, including without limitation: 

• discrimination, harassment, and creation/fostering of a hostile environment, 
• pervasive and systemic issues, 
• student handbook and policy violations, 
• employee handbook violations,
• non-policy violations,
• breaches of community trust, 
• concerns regarding course selection, placement, and course offerings, grades and comments, curriculum and program, 
• issues between students, 
• issues between students/parents/guardians and employees, 
• issues between faculty/employees,  
• issues concerning visitors/guests, volunteers, contractors, vendors and other non-employees, and
• Diversity, Equity, and Inclusion (“DEI”) Complaints

The Policy applies to in-person conduct that occurs on and off of School grounds, including locations such as field trips, athletic activities, and events for School clubs, as well as conduct that occurs through electronic communications, including social media, email, texts, phone and video conference. Even misconduct that occurs outside of School, during “personal time,” could have continuing effects in the School, and therefore is covered by the Policy.

The School may be limited in what actions it may take when investigating or responding to a complaint if an accused individual is not affiliated with the School or is no longer affiliated with the School at the time the complaint is made.  In such cases, the School will still, to the best of its ability, conduct an investigation where warranted, take steps to prevent the recurrence of misconduct to the extent it is able, and remedy the effects, where appropriate to do so.  The Complaint Management Process and any decisions made under it do not give rise to legal rights or obligations on the part of the School to pay compensation based on a decision made according to this process or for any deviation from the process. 

DEI Complaints generally arise from conduct that is motivated (in whole or in part) by the offender’s bias against another’s race, religion, disability, ethnic origin, nationality, citizenship status, sex, sexual orientation or gender identity including the following:

• Using hate symbols or hate speech
• Using derogatory terms or derogatory language, including but not limited to racial slurs 
• Making comments that are insensitive or demonstrate that the offender holds a prejudicial bias
• Words or actions that incite an individual or group of individuals to cause harm, whether intentionally or unintentionally to another or others, including those in a protected class
• Events or activities that encourage people to wear costumes and act out in way that reinforces stereotypes and creates a campus climate that is hostile to racial and ethnic groups
• Pejorative comments or stereotypes about a protected class of people, i.e. females, religious minorities, racial minority groups, or people with disabilities
• Making sexual comments, jokes or gestures; displaying sexually inappropriate images 
• Intentionally misgendering an individual or using incorrect pronouns, having knowledge of an individual’s preferred pronouns 
• A physical attack or property damage, where the attack or damage was done because of the offender’s bias 
• Ridiculing another’s language or accent
• Bullying and/or harassing  behavior that is severe, persistent, or pervasive to the point that it threatens an individual’s ability to work, study or participate in the School Community

DEI Complaints can be reported using the same methods as all other complaints and are documented, recorded, and investigated pursuant to the Policy and the procedures described below. DEI Complaints are also recorded and documented by the Accountability and Compliance Subcommittee (ACS), a subcommittee of the Diversity, Equity, and Inclusion Advisory Committee.  

The Assistant Head of School shall be responsible for the Complaints Management Process and shall hereinafter be referred to as the Complaints Management Officer (“CMO”).  The CMO is responsible for facilitating training on the Complaints Management process for both students and employees.

The School encourages all members of the School community to promptly communicate any questions, issues, or concerns.  Some issues may not initially rise to the level of a complaint, such as grading concerns, course selection or course offering issues, and questions regarding the School’s curriculum and program.  Individuals seeking to resolve these types of issues are encouraged to do so informally by speaking with the appropriate School employee or representative.  If the issue remains unresolved, an individual may utilize the Complaints Management Process. 

Community members can report complaints in person, by telephone, or in writing in the following ways:  

• By using the Complaint Form on the School Website; 
• By reporting to the Complaint Management Officer via email, telephone, or in-person; or
• By reporting to any School Employee via email, telephone, or in-person

Any individual who receives a complaint under the Policy shall acknowledge receipt of the complaint by notifying the Reporting Individual, prepare a written summary of the complaint, promptly record it in the Complaint Tracking System, and submit it to the CMO.  The CMO will refer the complaint to a Complaint Lead for follow-up and, if needed, investigation.

All complaints must be made in good faith (i.e., the complaint is based on a sincere and honest belief that a policy violation or other misconduct has occurred).  Complaints should never be filed in an attempt to harm or retaliate against another person.  If an investigation reveals that any individual knowingly or maliciously made a false complaint, the School will take all appropriate action.

Complaints can be made anonymously via the online Complaint Form.  Individuals submitting  an anonymous complaint should be aware that failure to disclose identifying information about the identities of the parties involved or the facts and circumstances regarding the complained of conduct, issue, or incident (including the names of any witnesses) severely limits the School’s ability to respond and remedy the effects of the misconduct.  Anonymous reports that provide enough information to constitute suspected ongoing abuse or neglect of a minor will still be reported to child protective services and/or local law enforcement.

Upon receipt of a complaint from the CMO, the Complaint Lead will conduct a preliminary inquiry to determine whether a formal investigation is necessary.  Some types of complaints may be able to be resolved after the preliminary inquiry – through informal mediation, restorative justice measures, or some other means.  As part of the preliminary inquiry, the Complaint Lead will meet with the victim/target of the complained of conduct, issue or incident (the “Complainant”) and the person against whom the complaint was reported (the “Respondent”).   

If the complaint can be resolved after the preliminary inquiry, the Complaint Lead will prepare a written summary of the findings, including the resolution, recommended corrective action, if any, and notify the Complainant and the Respondent. This information will then be recorded in the Complaint Tracking System.  If, however, the complaint cannot be resolved informally, the Complaint Lead will initiate a formal investigation, which may be conducted by the Complaint Lead themselves or another appropriate investigator within the School.  In some instances, the Complaint Lead, in consultation with the CMO, may determine that the complaint should be investigated by experienced outside  investigators.

The formal investigation will include interviews of the involved parties and witnesses, and the collection of written or other evidence, including statements from the parties or witnesses.

The Complaint Lead will notify the Complainant and Respondent, in writing,  of the investigation’s conclusion and the final determination.  If, at the formal investigation’s conclusion, the School determines that a preponderance of the evidence supports a finding that an individual has engaged in conduct in violation of the law or any School policy, the individual will be subject to restorative justice, educational intervention strategies, corrective action, and/or disciplinary action.  If disciplinary action results, both the Complainant and the Respondent may appeal the determination.  The party who wishes to appeal the School’s disciplinary decision may ask questions or provide new or different information to the Head of School within 10 days of the School’s final determination.

At the conclusion of a formal investigation, the Complaint Lead will prepare a written summary of the findings, including the final resolution, and record it in the Complaint Tracking System.

Community members who bring complaints or concerns to the School’s attention in good faith should do so without fear of reprisal.  RCDS strictly prohibits retaliation against any individual who makes a complaint under the Policy, or who provides information or otherwise participates in an investigation relating to such complaints or reports.  All individuals should promptly report any acts of perceived retaliation directly to their Division Principal, supervisor, supervising administrator, Assistant Head of School, Associate Head of School, or the Head of School. 

Complainants may request that the School shield their identity from the individual they are accusing of misconduct.  If an individual requests this type of confidentiality, the School will weigh the request against the School’s obligation to provide a safe, non-discriminatory environment for all members of its community.  The School will try to honor these requests, but it is not always possible to do so. 

Regardless of whether an individual requests confidentiality, the School will make every effort to prevent disclosure of the names of all the parties involved – the reporting individual, the Complainant, the witnesses, and the Respondent – except to the extent necessary to carry out an investigation.

Confidentiality cannot be guaranteed when an individual makes a complaint to a School employee, including school counselors and the school nurse, alleging child abuse or maltreatment.  All employees of the School are mandatory reporters, and as such must report suspected abuse of both current and former students or employees, no matter when they become aware of such concerns or allegations.  Any complaints that allege incidents of child abuse or neglect must be reported to Child Protective Services in accordance with the School’s mandatory reporting policy. 

If a complaint involves a student, the School has sole discretion to determine the stage of the complaint process in which the student’s parent/guardian is notified.  Parent(s)/Guardian(s) may be notified at any point during the complaint investigation process, including upon receipt of the complaint; at the preliminary inquiry stage or if the complaint is referred to the Disciplinary Committee; at the formal investigation stage; or at the resolution stage (including resolution that could involve suspension or expulsion).

The School is not a legal setting and therefore individuals involved in investigations will not be permitted to invite legal counsel into any interviews or disciplinary meetings.

While each complaint alleging conduct that arises to a potential systemic issue will be investigated individually, the School will also address systemic issues by notifying the Head of School of the systemic issue.  The Head of School, the CMO, and other parties (at the School’s discretion) will meet with the relevant supervisor/Department Head and agree on a strategy for resolving the systemic issue.