The document discusses a new harassment policy developed by the Central European University, which aims to improve the reporting and handling of harassment complaints. Key innovations include a network of trained ombudspersons to manage complaints and a centralized, anonymous complaint submission system. The policy addresses challenges such as underreporting, accountability, and compliance with GDPR while also preparing for implementation and training needs.

1. Combating Harassment: Policy Innovations
A n a B e l é n A m i l | G e n d e r E q u a l i t y O f f i c e r
C e n t r a l E u r o p e a n U n i v e r s i t y | S U P E R A
“This project has received funding from the European Union’s Horizon 2020 research and
innovation programme under grant agreement No 787829”.

2. • Central European University Harassment Policy (2013)
• 2 types of complaints:
formal
informal
• Dozens of people with no training responsible for receiving
complaints and mediating a solution
• Policy relied heavily on adversarial procedures
BACKGROUND

3. THE ASSESSMENT
Underreporting
problem
Less than 3% of
incidents
reported
Lack of
institutional
trust; fear of
retaliation
Lack of record
keeping
Reports
nowhere to be
found
Impossibility of
monitoring
Lack of
accountability
Insufficient
training
No training for
people who take
complaints
No training for
the wider
community

4. WORKING GROUP: THE SET UP
• Gender Equality Officer (GENS)
• Chair of the Equal Opportunity
Committee (SPP)
• Two members of the EOC (LEGS/SPP)
• Member of the Senate (POLS/PHIL)
• Chair of the Disciplinary Committee (SPP)
• Dean of Students
• Two PhD students (HIST)

5. THE IDEAS
Ombudspersons
Network (ON)
Highly
specialized
training
Receive (1)
and resolve
(2) informal
complaints
Guide the
complainant
throughout
the process
5 elected
members of
the
community
APP
Centralized
recording
system
Anonymous,
informal and
formal
complaints
Online, 24/7,
safe platform
to submit
complaints

6. THE IDEAS (II)
Anonymous
complaints
“Complaint
collectives”
Notification
to ON after
3+
complaints
No
disciplinary
sanction
Detect
patterns of
behavior

7. THE INSTITUTIONAL PROCESS
1 Consultation
with IT
First draft with
principles of
new Policy
finalized
SLT, Academic
Forum, Senate
2
Meeting with
Legal Counsel
(GDPR and
other matters)
Amendment
of the Policy
(working
group)
Policy checked
by Austrian
legal firm for
compatibility
MAIN CONCERNS/RESISTANCES:
× Security of the server
× GDPR compliance
× Potential lawsuits coming from the alleged harasser as a result of
the action of the ON
× Financial / time investment (APP)
× “Witch-hunt”, false accusations, explosion of complaints

8. THE INSTITUTIONAL PROCESS (II)
Final version
ready
GDPR team
comments on
expiration of
record-keeping
Academic Forum
and Senate
3
MAIN CONCERNS/RESISTANCES:
× GDPR compliance
× How to do fact-finding 3 years after the incident
× Subjectivity in determining what constitutes harassment/ difference between improper conduct
and harassment

9. IMPLEMENTATION CHALLENGES AHEAD
• APP development
• Careful alignment with GDPR
(data flow!)
• Election of the ON
• Finding training providers
• Financing training

10. THANK YOU VERY MUCH!
Q&C welcome
A n a B e l é n A m i l | G e n d e r E q u a l i t y O f f i c e r
C e n t r a l E u r o p e a n U n i v e r s i t y | S U P E R A
“This project has received funding from the European Union’s Horizon 2020 research and
innovation programme under grant agreement No 787829”.