1. Take the complaint from the target. Express no opinion and make no commitment regarding the outcome of the investigation. Be an active listener, asking questions, acknowledging the complainant's statements and repeating his/her feelings. Encourage the complainant to be as factual as possible. Try to obtain names of witnesses or individuals the complainant told about the alleged discrimination or harassment. Find out if the target communicated to the accused individual that the conduct was unwelcome. Ask if work environment has turned hostile because of this undesired behavior.
2. Tell the complainant that you will protect his/her privacy as much as possible but that you will need to investigate the complaint. Tell him/her that the College will not permit retaliation against the complainant either for
a) making the complaint or
b) for complaining about the actions of a supervisor or co-worker.
Document everything!
3. Interview the alleged respondent. Conduct the interview the same way you did for the complainant. Ask questions in an unbiased manner, encouraging the accused individual to give her/his version of the facts. If the alleged respondent admits that the conduct occurred, discuss the violation of the College's policy and tell the individual that you may wish to speak with him/her further. Alert the respondent's immediate supervisor for determination of discipline.
4. If the alleged respondent denied the allegations, initiate an investigation, after alerting the accused individual's supervisor. Be discreet, enlist College resources, review appropriate records and interview anyone who may have information or insights on what took place.
5. Try to determine whether other individuals may have been discriminated against and/or harassed by the accused individual. Even if this complaint does not appear to have a strong basis in fact, others might come to light.
6. Make a recommended finding of fact, stating what evidence your conclusions are based upon. If you cannot determine whether or not the harassment occurred, say so.
7. To the degree possible, respond as quickly as possible, but do a thorough job. Although the investigation should begin shortly after the complaint, it should not be closed until all relevant witnesses and records have been identified and reviewed.