Harassment and Discrimination Prevention and Response Policy

Approval: Board of Trustees

Responsibility: Vice‐Principal (Culture, Equity, and Inclusion) ("VPCEI")

Date: Approved : May 7, 2021 / Effective September 1, 2021

Revised : May 12, 2023; September 29, 2023; May 9, 2025, Effective September 1, 2025;

To file a complaint or report, or for FAQs and training modules, click here


TABLE OF CONTENTS

1.      Purpose / Reason for Policy

2.      Policy Statement

3.      Confidentiality

4.      Scope of this Policy

5.      Resources and Information when Considering Filing a Complaint or Report

6.      Roles and Responsibilities 

7.      Policy Review and Reporting 

8.      University Resources and Information Specifically Addressing Racism and Hate

9.      Effective Date

APPENDIX 1:  GLOSSARY OF TERMS

APPENDIX 2:  POLICY FLOWCHART

APPENDIX 3:  COMPLAINT PROCEDURE FLOWCHART 

APPENDIX 4:  REPORTING PROCEDURE FLOWCHART


Capitalized terms used in this policy are defined in the Glossary of Terms.

1. Purpose/Reason for Policy

1.1 This Policy supports the prevention of HarassmentDiscrimination and Reprisal at the University and the effective response to Reports and Complaints of Harassment, Discrimination, and Reprisal.

1.2 This Policy also aims to address all forms of racism and hate through educations; when racism and hate manifest in conduct or comment by members in the University Community that constitute Harassment or Discrimination, the Complaint and Reporting Procedures are also available.

1.3 The processes supporting this Policy include a Complaint Intake and Investigation Procedure, a Reporting Procedure, and an anonymous reporting process.

a. Complaint Intake and Investigation Procedure:

  • Individuals (“Complainant”) who feels they have experienced Discrimination, Harassment or Reprisal can file a Complaint under the Complaint Intake and Investigation Procedure
  • Individuals who are unsure whether their experience involved Harassment, Discrimination, or reprisal and/or who are considering filing a Complaint are strongly encouraged to seek advice before doing so (See Section 5, below); 
  • The University has a Policy on Sexual Misconduct and Sexual Violence Involving Students (the “Sexual Violence Policy”) that describes how Complaints of sexual misconduct and sexual violence (which includes Sexual Harassment) involving students will be handled.  If a matter relates to Sexual Misconduct, Sexual Harassment or another form of sexual violence (as defined in the Sexual Violence Policy), and involves a student, either as a Complainant or a Respondent, a Complaint under this Policy should not be filed, even if the matter also contains allegations of other forms Harassment or Discrimination as defined in this Policy; rather, the procedure set out in the Sexual Violence Policy must be followed, but an outcome under that procedure could include a finding of a breach of this Policy). Students are encouraged to contact Sexual Violence Prevention and Response Services for support and advice (svprservices@queensu.ca).

b. A Reporting Procedure:

  • Individuals who witness or becomes aware of Harassment, Discrimination, Reprisal or Systemic Discrimination (“Reporter”)are encouraged to submit a Report under the Reporting Procedure.
  • A Person of Authority who witnesses or becomes aware of Workplace Harassment must submit a Report.  A Person of Authority may, for example, become aware of an incident by witnessing it, or, by being informed about it by another person who witnessed it.

c. In-Sight: Available here on the Human Rights and Equity Services website, the In-Sight Tool provides University Community members with an anonymous process for reporting Harassment, Discrimination, and Bias/Hate Incidents.  Information from anonymous submissions collected through IN-SIGHT is used to help the University generate a more accurate picture regarding how harassment, discrimination, or bias/hate related incidents affect ֱ community members, and also helps identify trends (new and recurring) that are used to inform policy, programming, services and future anti-racism and other discrimination/harassment prevention and response initiatives at ֱ (“Queen’s” or “the University”).

2. Policy Statement

2.1 Excellence in teaching, learning, research, scholarship, and the service of the University in and to the community at large, the nation, and the community of nations can only be achieved when all members of the University Community are free to live, learn, and work in an environment free from Harassment or Discrimination, and Reprisals. 

2.2 ֱ is an environment where Harassment, Discrimination and Reprisal are prohibited. This includes conduct based on one or more protected grounds listed in the including: race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, record of offences (employment only), marital status, family status, and disability. 

2.3 Those who engage in Harassment, Discrimination or Reprisal will be subject to corrective actions, which may include the imposition of discipline in an employment context, up to and including termination from employment, and/or a requirement for a student to withdraw from their studies at the University.

2.4 Queen’s will respond to Complaints and Reports fairly and promptly.

2.5 Queen’s will endeavour to resolve concerns about Harassment, Discrimination, and Reprisals and will be proactive in the removal of identified systemic barriers.

2.6 Queen’s will keep Complainants and Respondents reasonably apprised of the status of investigations.

2.7 Making Complaints or Reports in bad faith or taking action to undermine the purpose of this Policy is prohibited and will be subject to corrective action.

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3. Confidentiality

3.1 Queen’s will respect the privacy of individuals involved in Complaints and Reports. 

a. Personal information collected under this Policy and its Procedures is confidential and will only be used and/or disclosed to investigate, take corrective action and to protect health and safety, or as ordered by a body with jurisdiction to do so.

b. The University’s commitment to confidentiality also means that:

  • documents created under this Policy will be maintained in secure files;
  • documents related to a Complaint will not be included in the personnel file of any employee Complainant;
  • except for any disciplinary measures imposed (e.g., verbal/written warning(s), letter(s) of discipline, etc.) or required remedial action(s), documents related to the Complaint will not be included in the personnel file of any employee Respondent(s);
  • only authorized individuals will have access to documents created under this Policy or its Procedures, on a need-to-know basis; and,
  • reasonable steps will be taken to protect against unauthorized access to electronic documents.


c. All individuals involved in an investigation process will be advised of their duty to maintain the confidentiality of all information disclosed to them or by them, including personal information.

3.2 Limits on Confidentiality 

a. The University will disclose information as needed to implement interim measures and to fairly investigate Complaints and Reports, or to pursue Early Resolution options outlined in Section 5.

b. The University will also share identifying information in circumstances where it is necessary to administer this Policy, to address safety concerns, or to satisfy a legal reporting requirement, including in the following circumstances (this is not an exhaustive list):

  • an individual is at risk of harm to self or others; 
  • there are reasonable grounds to be concerned about risk of violence or the safety of the University Community or broader community; 
  •  disclosure is required by law, for example, suspected abuse of someone under the age of 16, to comply with the Ontario Occupational Health and Safety Act, Workplace Safety and Insurance Act, Human Rights Code, or other legislation; and/or 
  • to comply with the reporting requirements of regulatory bodies and/or professional licensing bodies.

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4. Scope of this Policy

4.1 This Policy covers Harassment, Discrimination and Reprisal where:

  • the conduct takes place on University Property;
  • the conduct takes place at a University-sponsored event or the conduct has a direct connection to a University-sponsored event, such as a conference, or other specific event, or University business;
  • a University community member engages in conduct while representing or claiming to represent the University or an organization formally affiliated with the University; or,
  • the University has reasonable grounds to believe the conduct creates a risk to the health or safety of a member(s) of the University Community in the University’s living, learning, or working environments.

4.2 This policy does not apply to employees of Bader College, who shall be governed by policies and procedures as enacted by the College.

4.3 This policy does apply to students and employees of Queen’s while studying, working, or living at Bader College; in those cases the University is empowered to modify this Policy or its applicable Procedures to comply with the legal requirements of the United Kingdom.

4.4 This Policy and its Procedures do not override or diminish the rights provided to employees under collective agreements.  Where there is a conflict between this Policy or its Procedures and a collective agreement, the terms of the collective agreement govern.

4.5 Every bargaining unit member has the right to advice and assistance from their union at any point in a process under this Policy. An employee attending an interview or meeting convened under this Policy may bring a union representative as their Advisor.  (See Section 35 of the Complaint Intake and Investigation Procedure for a description of “Support Person” and “Advisor.”)

4.6 This Policy does not preclude individuals from pursuing processes external to the University, including those available through the Human Rights Legal Support Centre, the police, the Ontario Labour Relations Board, or the Human Rights Tribunal of Ontario.

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5. Resources and Information when Considering Filing a Complaint or Report 

5.1 Consultation when considering a Complaint or Report under this Policy is not required but is strongly encouraged because it has several advantages, such as:

  • identifying an early and efficient opportunities to clear up what might be a misunderstanding;
  • identifying ways of facilitating internal communication, which in turn can help strengthen relationships; 
  • identifying issues that may not constitute Harassment or Discrimination or Reprisal, but may nevertheless require discussion and resolution among individuals or groups;
  • avoiding escalation of issues because of assumptions, misunderstandings, etc. that might otherwise be effectively addressed through discussion and collaboration. 

5.2 University Community members are encouraged to consult with University resource offices as follows:

a. the Office of the University Ombudsperson or the Complaints & Investigations Office for general information about the Policy and its Procedures.
b. the HREO about concerns related Human Rights Code matters, such as Discrimination and Discriminatory Harassment. 
c. the Complaints & Investigations Office for concerns related to Workplace Harassment and non-Human Rights Code issues related to employee conduct

  • Employees are also encouraged to consult with their manager/supervisor for advice/assistance. 
  • Managers and Supervisors are encouraged to consult their or a member of the Labour Relations Team in the Faculty Relations Office, as applicable, for matters related to employee conduct.

d. the Non-Academic Misconduct Intake Office (“NAMIO”) about non-Human Rights Code issues related to student conduct. 

5.3 University Community members who believe they have been subjected to Discrimination, Harassment or Reprisal are also encouraged, although not obliged, to make it known to the other person that their behaviour is unwelcome, if they believe they can do so safely.  

5.4 Any person seeking information/advice from the above resource offices will be told about:
a. this Policy and the definitions of Harassment, Discrimination, and Reprisal; 
b. the options available to resolve their concern, including early resolution described below (see 5.8 and 5.9), the Complaint Intake and Investigation Procedure and the Reporting Procedure; and,
c. “Confidentiality” and the “Limits on Confidentiality” set out in Section 3, above. 
 

5.5 Subject to 5.7 (a) and (b) below about Reports filed by Persons of Authority, those wishing to file a Complaint or Report without first consulting a resource office may do so directly using one of the forms found here.

5.6 If the HREO or the Complaints & Investigations Office are consulted about issues related to Workplace Harassment, they must consult with Human Resources or Faculty Relations to ensure the requirements of any applicable collective agreement and of the Ontario Occupational Health and Safety Act are met.  

5.7 Workplace Harassment and Persons of Authority
a. Prior to filing a mandatory Report about Workplace Harassment of a staff member, a Person of Authority must consult with the appropriate . 
b. Prior to filing a mandatory Report about Workplace Harassment of a faculty member, a Graduate Teaching Assistant or Teaching Fellow, or a Postdoctoral Fellow, a Person of Authority must consult with the Faculty Relations Office

5.8 Following consultation, resource offices, subject to 5.6 above and with the consent of the Complainant(s) and the Respondent(s) may attempt early resolution.  If the concern is resolved at the consultation stage, the resource office primarily involved in reaching the resolution (i.e., the HREO, the Complaints & Investigations Office, Human Resources, Faculty Relations, or the Office of the University Ombudsperson) must provide the Vice-Principal (Culture, Equity and Inclusion) with a brief, anonymized summary of process followed and the terms of resolution for the purposes of Policy administration and of recording statistics and trends. 

5.9 If a Resolution is not achieved at this stage, the option to submit a Complaint or remains available.  If a Complaint or Report is filed and is referred for investigation, the content of any early resolution discussions cannot be disclosed to the investigator, except for any agreed statement of facts that was achieved during the consultation stage. This restriction does not apply when an investigation is about an alleged breach of a resolution reached at the consultation stage. 

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6. Roles and Responsibilities

6.1 All members of the University Community
a. It is the responsibility of all members of the University Community to:

  • strive to create an environment free of Harassment and Discrimination in their areas of responsibility and in their interactions with others;
    • understand that behaviours influenced by, or that demonstrate evidence of, conscious or unconscious bias, prejudice, negative stereotypes, racism, or hate are often the root cause of Harassment and Discrimination; they can harm members of the University Community, negatively impact their participation in the University’s living, learning, or working environments.  The University's approach to combatting such attitudes will often be remedial and will include education and initiatives to advance equity, diversity, inclusion, anti-racism, and indigenization on campus, but if they manifest in conduct or comment, the Complaint and Reporting Procedures and/or other applicable policies, procedures guidelines and initiatives will be applicable
  • be informed about what constitutes Harassment, Discrimination and Reprisal;
  • familiarize themselves about the Procedures for dealing with allegations of Harassment, Discrimination and Reprisal;
  • cooperate with investigations conducted under this Policy.  

 

Bias, prejudice, negative stereotypes, racism, or hate associated with acts of Harassment, Discrimination or Reprisal, are among the aggravating factors that will be considered in determining the appropriate sanction(s).

b. Employees, students, volunteers,  visitors and contractors are encouraged to use the Reporting Procedure to report incidents of Harassment, Discrimination, or Reprisal when they witness such incidents.

c. Employees and volunteers shall, and students and visitors are expected to, participate in any investigation commenced under the Policy.

d. Contractors who believe they have been subjected to Harassment or Discrimination while working on University Property or while engaged in activity for the University must first raise the issue with their employer.

6.2 Person(s) of Authority

a. The Principal’s Senior Leadership Team, senior administrators and all Persons of Authority will take steps to prevent Harassment and Discrimination, act when they become aware of instances of Harassment and Discrimination, and support and promote this Policy and its Procedures.

b. Queen’s will ensure Persons of Authority are provided with information and instruction that will enable them to recognize, assess, and address Workplace Harassment and Discrimination, and to understand how to respond appropriately when such incidents come to their attention.

c. Persons of Authority must submit a Report to the VPCEI with respect to incidents of Workplace Harassment, if after the consultation required under 5.7 above they conclude that they have witnessed or have otherwise been advised about an incident of Workplace Harassment by someone who witnessed it.

d. Persons of Authority must also submit a Report if they become aware of a policy, process, or other circumstance they believe gives rise to Systemic Discrimination. 

e. Disclosure of information about Workplace Discrimination, Harassment, or Reprisal to a Person of Authority is not intended to be used as a proxy for a person who believes they have experienced Workplace Discrimination, Harassment, or Reprisal not using the Complaint Intake and Investigation Procedure.

6.3 The Office of the Vice‐Principal (Culture, Equity, and Inclusion) ("VPCEI")

a. The VPCEI receives all written Complaints and Reports under this Policy on behalf of the University.  

b. The mandate of this office does not include providing advisory services about Harassment and Discrimination or about issues related to this Policy and its Procedures. For such advisory services, refer to 6.4-6.8 below. 

c. The VPCEI is the Chair of the Intake Assessment Team.

d. The VPCEI receives reports, per the Complaint Intake and Investigation Procedure, of Systemic Discrimination.

e. The VPCEI keeps records of all Reports, Complaints, and early resolution agreements/arrangements for the purposes of policy administration and recording statistics and trends.  Records are retained/disposed of in accordance with .  (Related records held by Student Affairs in connection with the administration of student non-academic misconduct, are retained/disposed of in accordance with ).

f. The VPCEI is responsible for maintaining this Policy and its related Procedures.

6.4 The Human Rights and Equity Office ("HREO")

a. In collaboration with campus partners, HREO is responsible for awareness-raising and training initiatives aimed at preventing and addressing Discrimination, Systemic Discrimination, and Human Rights Code-based Harassment (i.e., Discriminatory Harassment), addressing underlying ideologies and conduct that may give rise to oppression (e.g., ageism, ableism, racism, sexism, hetero/cis sexism) and promoting an inclusive campus that exemplifies a climate of understanding and mutual respect for all members of the University Community.

b. The Associate Vice-Principal (Human Rights, Equity, and Inclusion) may review the policies and procedures implicated in a Report of Systemic Discrimination and provide recommendations about changes to address Systemic Discrimination embedded in those policies and procedures.

c. HREO is available to the entire University Community to provide training, information, and guidance with respect to policies, procedures, publications, and materials to ensure that they do not include terms that are discriminatory or have a discriminatory effect.  However, such education is a broader responsibility that requires many units and/or individuals across the University, including academic leaders, Environmental Health and Safety (“EH&S”), Human Resources, Faculty Relations, Staff Managers and Student Affairs, to cooperate and collaborate with Human Rights Advisory Services in this endeavour.

d. HREO is also available to provide information to individuals who feel that they have been subject to Discrimination or Discriminatory Harassment, and to individuals who believe they have witnessed or become aware of Harassment, Discrimination, Reprisal or Systemic Discrimination, and to ensure such individuals are fully aware of this Policy and its related Procedures.

e. The service is confidential, although HREO provides broad advisory services, with an important responsibility for helping maintain a living, learning, and working environment on campus that is safe and free of Discrimination and Discriminatory Harassment. This may require the sharing of information in certain circumstances, and HREO will balance the competing concerns in deciding when and how to share information, including by making a Report under the Reporting Procedure

f. HREO serves as a resource office for members of the University Community per Section 5 of this Policy.

g. HREO may initiate a Report or assist a Complainant with preparing a Complaint but does not adjudicate Complaints or initiate the Complaint Intake and Investigation Procedure, nor does it serve as an advocate for any individuals involved in a matter under this Policy.

6.5 The Office of the University Ombudsperso

a. The Office of the University Ombudsperson is an institutional resource office with a mandate that includes advising employees and students about processes and procedural issues related to this Policy and its Procedures. This may include, for example, providing general, process-related advice to a witness or Respondent involved in an investigation under this Policy.

b. The office serves as a resource office for members of the University Community per Section 5 of this Policy.

c. The Ombudsperson does not adjudicate Complaints or initiate the Complaint Intake and Investigation Procedure on behalf of individuals, nor does it serve as an advocate for any individuals involved in a matter under this Policy.

6.6 Complaints & Investigations Office

a. This office is an Investigating Office for the purposes of this Policy and its related Procedures.  It investigates Complaints and Reports referred to it by the Intake Assessment Team or, as appropriate, engages external investigators to do so and is the University’s primary point of contact with those investigators for process and file management issues related to their investigations.    

b. The office consults with, among others, Campus Security and Emergency Services, the Department of Environmental Health and Safety, Faculty Relations, and Human Resources, as appropriate, when undertaking or managing an investigation referred to it by the Intake Assessment Team.   

c. The office serves as a resource office for members of the University Community per Section 5 of this Policy.

d. The office is available to assist University Administrators and Departments whose mandates include an investigatory function under another Queen’s policy or procedure.

6.7 Human Resources

a. Human Resources, in conjunction with Environmental Health and Safety, Faculty Relations, and the Complaints & Investigations Office, is responsible for providing managers and staff with appropriate information and instruction with respect to Workplace Harassment and Discrimination, including notifying them of this Policy and its related Procedures.

b. Human Resources may submit a Report in response to reliable information it receives concerning Workplace Harassment, Discrimination, or Reprisal or if it becomes aware of a policy, process, or other circumstance it believes gives rise to Systemic Discrimination, but disclosing information about Workplace Harassment, Discrimination, or Reprisal to a member of the Human Resources Department is not intended to be used as a proxy for a person who believes they have experienced Workplace Discrimination, Harassment, or Reprisal not using the Complaint Intake and Investigation Procedure.

c. Human Resources will ensure that access to this Policy and related Procedures is available on the Human Resources website.

d. Human Resources serves as a resource office for members of the University Community per Section 5 of this Policy.

6.8 Faculty Relations Office

a. The Faculty Relations Office, in conjunction with EH&S, Human Resources, and the Complaints & Investigations Office, is responsible for providing faculty members and other academic staff with appropriate information and instruction with respect to Workplace Harassment and Discrimination, including notifying them of this Policy and its related Procedures.

b. The Office may submit a Report in response to reliable information it receives concerning Harassment, Discrimination, or Reprisal or if it becomes aware of a policy, process, or other circumstance it believes gives rise to Systemic Discrimination, but disclosing information about Workplace Harassment, Discrimination, or Reprisal to a member of Faculty Relations is not intended to be used as a proxy for a person who believes they have experienced Workplace Discrimination, Harassment, or Reprisal not using the Complaint Intake and Investigation Procedure.

c. The office serves as a resource office for members of the University Community per Section 5 of this Policy.

6.9 Non-Academic Misconduct Intake Office ("NAMIO")

a. The NAMIO is a Receiving Office for the purposes of this Policy and its related Procedures.  It receives investigation referrals for the purposes of this Policy and its related Procedures.  Complaints and Reports alleging a student(s) engaged in conduct contrary to this Policy will, if referred for investigation, normally be directed to the NAMIO, to be assessed and assigned to the appropriate Investigating Office (i.e., the Student Conduct office or other NAM Unit) under the Student Code of Conduct and its Procedures).   NOTE:  This does not apply to professionalism concerns regarding student(s) enrolled in a Program in the Faculty of Education or in the Faculty of Health Sciences - See the Complaint Intake and Investigation Procedure: “Student Professionalism Concerns” and “Conduct of Students in the Postgraduate Medical Education Program”)

6.10 Department of Environmental Health and Safety ("EH&S")

a. EH&S has the primary responsibility for overseeing compliance with the Occupational Health and Safety Act, including requirements related to Workplace Harassment.

b. EH&S, in conjunction with Human Resources, Faculty Relations, and the Complaints & Investigations Office, is responsible for providing employees with appropriate information and instruction with respect to Workplace Harassment, including notifying them of this Policy and its related Procedures.

c. EH&S will ensure information and instruction is made available to Persons of Authority about their obligations under this Policy and its related Procedures, that will equip them to recognize, assess, and address Workplace Harassment. 

d. EH&S may submit a Report in response to reliable information it receives concerning Workplace Harassment, Discrimination, or Reprisal or if it becomes aware of a policy, process, or other circumstance it believes gives rise to Systemic Discrimination, but disclosing information about Workplace Harassment, Discrimination, or Reprisal to a member of Faculty Relations is not intended to be used as a proxy for a person who believes they have experienced Workplace Discrimination, Harassment, or Reprisal not using the Complaint Intake and Investigation Procedure.

e. EH&S will ensure that access to this Policy and its related Procedures is available on the established health and safety bulletin boards and its website.

6.11 Campus Security and Emergency Services ("CSES") 

a. CSES and Emergency Services is an Investigating Office for the purposes of this Policy and its related Procedures.  

b. CSES and Emergency Services supports the handling of Reports and Complaints by engaging with others in the development of appropriate interim measures and individualized safety plans.

c. CSES ordinarily receives referrals from the Intake Assessment Team in connection with Reports and Complaints about visitor conduct.

d. CSES may submit a Report in response to reliable information it receives concerning Harassment, Discrimination, or Reprisal or if it becomes aware of a policy, process, or other circumstance it believes gives rise to Systemic Discrimination, but disclosing information about Workplace Harassment, Discrimination, or Reprisal to a member of Campus Security and Emergency Services is not intended to be used as a proxy for a person who believes they have experienced Workplace Discrimination, Harassment, or Reprisal not using the Complaint Intake and Investigation Procedure.

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7. Policy Review and Reporting

7.1 The VPCEI will ensure that this Policy, and all related Procedures, are reviewed as often as is necessary, and in any event, at least annually. Human Resources, Faculty Relations, the Student Conduct Office, the HREO, the Complaints & Investigations Office, and EH&S will participate in comprehensive reviews, with EH&S being responsible for consulting with the University's Joint Health and Safety Committees, as appropriate.

7.2 Annually, the VPCEI will provide an anonymized report to the Board of Trustees, through the University Culture Committee of the Board, about the:

  • number and types of Complaints and Reports submitted under this Policy by:
    • students;
    • staff; and, 
    • faculty; 
  • categories of Complaints and Reports;
  • number of Complaints and Reports that did not proceed to investigation;
  • Human Rights Code protected grounds associated with Complaints and Reports;
  • remedial/disciplinary measures imposed;
  • involvement of law enforcement, if any; and,
  • timelines for processing and investigating Complaints and Reports; 

The annual report will be posted on the Vice-Principal’s webpage.

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8. University Resources and Information Specifically Addressing Racism and Hate

8.1 While not all comment or conduct that express dislike, disdain, or that discredit, humiliate, hurt or offend a person or group, will be considered hate speech under the Criminal Code, they might constitute Discrimination or Discriminatory Harassment under this Policy and the Ontario Human Rights Code (See Ontario Human Rights Commission, ).

8.2 Queen’s is committed to addressing racism and hate in the University Community through various initiative and educational resources, including:  

Please visit the HREO's Home Page for more detailed information. 

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9. Effective Date

9.1 The effective date of this Policy, its Complaint Intake and Investigation Procedure and its Reporting Procedure, shall be September 1, 2025.

9.2 The Senate Harassment/Discrimination Complaint Policy and Procedure and the Interim Workplace Harassment & Discrimination Policy were rescinded by the Board of Trustees.  Therefore, after the effective date of this Policy, all references to those prior policies in any other University policy or procedure shall be deemed to refer to this Policy and its Procedures and all other such policies and procedures shall be amended accordingly as soon as practical, but in any event no later than their next regular review.


Contact Officer: Associate Vice-Principal (Complaints & Investigations)

Date for Next Review: June, 2026

Related Policies, Procedures and Guidelines:

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APPENDIX 1:  GLOSSARY OF TERMS

1. "Discrimination":

a. is a distinction relating to personal characteristics of an individual or group based on a ground protected by the Ontario  that has the effect of imposing burdens, obligations or disadvantages on such individual or group not imposed upon others, or that withholds or limits access to opportunities, benefits, and advantages available to other members of society;

b. can be direct, indirect, or systemic in nature; 

c. does not require an intention to discriminate;

d. includes a distinction imposed because of a person’s or group’s relationship to, association with, or dealings with, another person or persons who are identified by a protected ground; 

e. includes a failure to accommodate the needs of individuals related to one or more grounds protected by the Ontario , unless doing so would cause undue hardship. The duty to accommodate must be fulfilled in accordance with the principles of dignity, individualization, and inclusion; 

f. does not include restricting membership in a special interest group that is primarily engaged in serving interests of people identified by a prohibited ground to people who are similarly identified (See Section 18 of the Ontario ). Similarly, Discrimination does not include admissions pathways at the University that are limited to, and designed for the benefit of, members of a group or groups that are protected by the Ontario Human Rights Code.

Systemic Discrimination” refers to policies, practices, patterns of behaviour or attitudes that are part of the social or administrative structures of an organization, and that while appearing neutral on the surface nevertheless have an “adverse effect” or exclusionary impact on people based on a ground protected by the Ontario  (see section 11 - "Adverse effect discrimination", and Fact Sheet).

Examples of Systemic Discrimination include:

  • not permitting time away from work or studies for religious or spiritual practices other than on statutory holidays;
  • less favourable differential career opportunities or career paths for qualified members of equity seeking groups;
  • failing to deal with discriminatory incidents or downplaying their seriousness because, for example, “no harm was intended.”

Protected grounds under the Ontario  include:

  • race
  • gender identity
  • ancestry
  • gender expression
  • place of origin
  • age (protected only in relation to those 18 years or older)
  • colour   
  • record of offences (protected in relation to employment only)
  • ethnic origin
  • marital status
  • citizenship
  • family status
  • creed
  • sexual orientation
  • sex
  • disability, and
  • any other ground that may subsequently be designated as protected under the Ontario 

2. "Harassment" means engaging in a course of vexatious comment or conduct that exceeds the bounds of free expression or academic freedom as these are understood in University policies (see for example the Queen’s  Free Expression Policy and Guidelines for Peaceful Protest) which is known or ought reasonably to be known to be unwelcome. While any form of Harassment normally requires a ‘course’ of conduct or comment, a particularly egregious, stand-alone incident that creates an oppressive environment could constitute Harassment. 

This includes not merely direct and intentional acts of Harassment but also includes engaging in verbal or non-verbal behaviour or communication that is known or ought to reasonably be known to be hostile, intimidating or threatening, or that deliberately seeks to control or manipulate or otherwise harm another person, and can include comment or conduct through any electronic media regardless of where it originates.  While it might be, Harassment need not be connected to a ground protected by the Ontario .                         

Things such as differences of opinion, personality conflicts, or personal disputes between individuals are not generally considered to be Harassment.

Harassment can take on a variety of specific forms; some commonly recognized forms include:

"Discriminatory Harassment" is a form of Harassment in which one or more grounds protected by the Ontario  is a factor. Discriminatory Harassment also includes Harassment based on a person’s relationship to, or association with, or dealings with, a person or persons identified by one or more protected grounds. Discriminatory Harassment may include, for example, racist jokes, conduct, or comment that negatively target or demean an individual’s or group’s ancestry, creed, ethnic origin, place or origin, sexual harassment, gender-based harassment and microaggressions.  

Harassment by Provocation or Incitement” is a form of Discriminatory Harassment involving public behaviour, comment or other written/graphic communication that exceeds the bounds of free expression or academic freedom as these are understood in University polices (see, for example, the ֱ Free Expression Policy and Guidelines for Peaceful Protest) which incites or encourages hatred, contempt for, or revulsion or severe ridicule of, a person or group of people based on one or more grounds protected by the Ontario  or because of a person’s relationship to, or association or dealings with, such a person or group.

"Sexual Harassment" is defined in the Ontario Occupational Health and Safety Act as a course of vexatious comment, conduct and/or communication of a sexual nature or based on sex, sexual orientation, gender, gender identity or gender expression that is known, or ought to have been known to be unwelcome. Depending on the circumstances, one incident could be significant or substantial enough for the University to consider it to be sexual harassment. 

Sexual harassment includes:

  • unwanted sexual solicitations, attention, advances, or comments and gestures (including songs and chants);
  • the display of sexually suggestive pictures, posters, objects, or graffiti;  
  • the implied or express promise of benefits or advancement in return for sexual favours;
  • threats of reprisals for rejecting unwanted solicitations or advances;
  • engaging in conduct or making a comments that creates a poisoned environment for individuals of a specific sex, sexual identity, gender identity or gender expression;
  • non-consensual posting of pictures, aggressive comments, and slurs of a sexual nature on any form of social media or other electronic media.;  
  • physical contact of a sexual nature (including sexual assault); and  
  • sexual conduct that interferes with an individual's dignity or privacy such as voyeurism and exhibitionism. 

Workplace Harassment” is defined in the Ontario as vexatious comment or conduct against a worker in a workplace that is known or ought reasonably to be known to be unwelcome. Workplace Harassment includes Sexual Harassment and Discriminatory Harassment in the Workplace.

  • Things such as differences of opinion, personality conflicts, or personal disputes between workers are not generally considered to be Workplace Harassment.
  • Reasonable action(s) taken by the University or by a Person of Authority relating to the management and direction of workers or the Workplace is not Workplace Harassment. Reasonable management actions could include things such as changes in work assignments, scheduling, job/performance assessment and evaluation, workplace inspections, implementation of health and safety measures, and disciplinary action. If these actions are not exercised appropriately, they may constitute Workplace Harassment.
  • Workplace Harassment can involve unwelcome words or actions that are known or should be known to be offensive, embarrassing, humiliating, or demeaning to a worker or group of workers, in a Workplace.
  • Workplace Harassment can also include behaviour that intimidates, isolates, or even discriminates against the targeted individual(s).  This may include: 
    • making remarks, jokes or innuendos that demean, ridicule, intimidate, or offend;
    • displaying or circulating offensive pictures or materials in print or electronic form;
    • bullying;
    • repeated offensive or intimidating phone calls or e-mails;

3. “Intake Assessment Team” is the group, chaired by the Vice-Principal (Culture, Equity, and Inclusion), responsible for the initial determination of whether the facts alleged in a Complaint or Report, assuming they are true, would constitute Harassment, Discrimination, or Systemic Discrimination (in a Report only), or a Reprisal (i.e., whether the facts alleged establish a prima facie case), and if so, for the referral to the appropriate Receiving Office

4. "Investigating Office" is the University Office tasked with conducting and investigation or managing a third-party investigation under this Policy. An Investigating Office may also be a Receiving Office.

5. "Person(s) of Authority" means any person who has supervisory, managerial, or administrative authority over a Queen’s employee who has apparently been subjected to conduct in breach of this Policy and/or over a Queen’s employee who has apparently engaged in conduct that breaches this Policy.

5. "Racism" is an ideology that either directly or indirectly asserts that one group is inherently superior to others.  It can be openly displayed in racial jokes and slurs or hate crimes, but it can be more deeply rooted in attitudes, values, and stereotypical beliefs.  In some cases, these are unconsciously held and have become deeply embedded in systems and institutions that have evolved over time. Racism operates at a number of levels, in particular, individual, systemic, and societal.  

Racism plays a significant role in fostering racial discrimination and harassment, but racism is a wider phenomenon than racial discrimination or harassment.  While the Ontario Human Rights Commission, the and Queen’s seek to combat racism through public education and the advancement of human rights, not every manifestation of racism can be dealt with through the current complaint mechanisms, or this Policy and its Procedures.  (see Fact Sheet and ).

6. “Receiving Office” is the University office to which a Complaint or Report has been referred for investigation.  This generally includes but is not necessarily limited to the Complaints & Investigations Office, Campus Security and Emergency Services, or the NAMIO. (the NAMIO will refer the case to the appropriate Investigating Office.

7. “Reprisal” means the act of penalizing, intimidating, or coercing an individual for acting in good faith to carry out or assist with any step provided for in the Complaint Intake and Investigation Procedure or the Reporting Procedure made under this Policy and includes threatening to do so. Engaging in an act of Reprisal constitutes a breach of this Policy and will be subject to disciplinary action up to and including termination from employment and/or a requirement that a student withdraw from studies at Queen’s. 

The imposition of discipline or other sanctions for making a Report or Complaint in bad faith is not an act of Reprisal.

8. "Respondent" refers to anyone who is alleged in a Complaint or Report to engaged in conduct prohibited by this Policy.

9. “University Community” includes employees, students, volunteers, visiting scholars, contractors, visitors, guest speakers, student groups, and other individuals who live, work, study at, or provide services to, the University.

10. “University Property” means property owned, rented, or otherwise used for a university event.

11. "Workplace" means any place where a Queen’s employee engages in employment activity.  This includes virtual/online workspaces, employment activities outside the normal place of work, and employment activities that occur outside of normal working hours.

 

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