COMMUNITY GRIEVANCE POLICY & FORM
This grievance policy is intended to provide a clear, transparent means for community members participating in activities facilitated by the Coru Cathubodua Priesthood to have addressed any acts of harassment or discrimination committed against them by an active Coru member.
If a person has any questions or concerns about this policy, they may contact the Coru at info@corupriesthood.com for discussion.
EQUAL OPPORTUNITY & SERVICES STATEMENT
It is the policy of the Coru Cathubodua Priesthood (“the Coru”) to provide equal services and opportunities to all persons regardless of gender identity, gender expression, sexual orientation, body shape, race, ethnicity, nation of origin, citizenship or immigration status, religion, socioeconomic status, disability, medical conditions, genetic information, pregnancy, marital status, or other protected or marginalized characteristic. Harassment and discrimination are prohibited in all aspects of the Coru’s business and activities, in accordance with California and Federal law.
The Coru is committed to maintaining community spaces in which all individuals are treated with respect and dignity. Each individual who participates in activities in which the Coru is the primary facilitator has the right to an environment that is free from harassment or discrimination. This also applies to individuals who are perceived to have any of the protected characteristics listed above, regardless of whether or not such perception is based in reality.
To uphold this commitment, the Coru is obligated to:
Review its policies and procedures regularly to ensure that they remain responsive to current Coru activities and community needs and feedback;
Pursue ongoing education for all of its members regarding equity and social justice with the permanent goal of developing, implementing, and improving organizational responsiveness to culturally specific needs;
Create opportunities for its community to provide feedback about the Coru as a collective or about its individual members using methods which are clearly defined, easy to access, transparent to the petitioner from start to finish, and which preserve confidentiality wherever possible;
Demonstrate appropriate, measurable change in policy and procedure where organizational failings have been shown.
DEFINITION OF TERMS
DISCRIMINATION
Discrimination is the differential treatment of an individual or group of people based on their personal characteristics which results in negative consequences on the well-being of the direct recipient or as collateral harm to individuals in proximity. These consequences can be physical, mental, or emotional in nature.
As a registered 501(c)3 church in the state of California, the Coru is legally bound to provide equal service and opportunities to all individuals with any of the protected characteristics listed here: https://calcivilrights.ca.gov/unruh/#whoBody
HARASSMENT
Under California law, harassment is defined as unlawful violence including assault, battery, and stalking; a credible threat of violence; or repeated actions that seriously alarm, annoy, or harass you and which serve no legitimate purpose. Harassment also includes unwelcome conduct that is based on a protected characteristic.
This would also include an individual being made to believe that their participation in Coru activities is predicated on tolerating offensive or other harmful behavior.
Sexual harassment is a particular type of harassment that includes unwelcome conduct such as sexual advances; requests for sexual favors or dates; remarks about an individual’s appearance; discussions, remarks, or jokes of a sexual nature; display of derogatory posters, cartoons, or drawings; and/or other verbal or physical harassment of a sexual nature.
RETALIATION
Retaliation involves a Coru member taking actions in response to a grievance which are intended to intimidate, threaten, or silence the person who has brought the grievance.
GRIEVANCE
A grievance is a formal written complaint about harassing or discriminatory conduct by a Coru member. This puts into motion the grievance process and necessitates a timely official response from Coru’s leadership. The written complaint can be submitted by a community member or by a Coru member who has a community member’s explicit consent to do so on the community member’s behalf. Individual community members as well as a group acting as a single collective party can file grievances. A group acting as a single collective is included wherever “petitioner” is being used as a singular noun.
Coru officers are required to investigate any grievance brought to their attention.
PETITIONER
A petitioner is the person or group who has been the recipient of harm and has chosen to engage the grievance process. This term is used in its neutral context and does not convey any predetermined positive or negative value.
RESPONDENT
A respondent is the person alleged to have caused the harm and who is responding to the allegation against them in the grievance. This term is used in its neutral context and does not convey any predetermined positive or negative value.
CONFLICT OF INTEREST
Conflict of interest arises where personal bias or emotional investment will interfere with an individual’s ability to fulfill the responsibilities of their role with reasonable assurance of objectivity. Examples of conflict of interest in this grievance policy:
The Chief is named as the respondent and so cannot serve as the default investigator;
Any officer is named as the respondent and so cannot participate in any part of the process that involves review and approval by a group of officers.
SCOPE OF THE GRIEVANCE PROCEDURE
At any time, a community member may choose to bring forth allegations of improper conduct against an active Coru member.
In cases where the respondent is not an active member of the Coru, the Coru may have reduced authority in addressing the harm and may be limited to the suspension or prohibition for that individual to participate in any future Coru activities. These cases are covered by our Statement of Hospitality and Safety.
A petitioner may choose any of the following options. The options may be chosen in any order.
Direct informal address. Where a violation has occurred, a community member may communicate directly with the Coru member who caused the harm. If the Coru member who caused harm acknowledges the violation and makes a good faith effort to repair the harm or avoid repeating it, and the community member is satisfied with the outcome, then the matter will be considered resolved unless and until that Coru member either repeats the original harm or commits a new form of harm. If the community member is not satisfied with the outcome, they may try engaging the Coru member again or choose any of the other options.
Collective informal address. A community member may enlist the assistance of a Coru officer for support in engaging with the Coru member who caused harm. This does not have to automatically begin a formal grievance process.
A community accountability process. The community member may choose to engage the Coru member in a community accountability process. In this instance, the process should be facilitated by a third party with experience in facilitating such processes. The Coru would not assume any facilitation responsibilities and would instead only participate as fellow community members. The Coru may still choose to take their own disciplinary action against the member who caused harm, such as suspending or terminating their membership. Choosing to engage a community accountability process under the facilitation of a third party does not automatically begin a formal grievance process.
Grievance process. Upon filing a verbal or written complaint with an active Coru member, the Coru will begin the formal grievance process outlined below.
TIME FRAME
A community member may bring forth a complaint at any time. For the Coru’s purposes, there is no statute of limitations.
However, the Coru does not retain any authority over former members. In a case where the harm was done by a former member, the Coru is obligated to review its own role in what occurred and evaluate what changes in its policies and procedures may be necessary to mitigate the risk of that harm occurring again with current and future members.
ROLES & RESPONSIBILITIES
CORU CHIEF
The Chief who is active at the time of filing, who may or may not be the Chief who was active when the alleged incident occurred, will be the default investigator unless conflict of interest requires otherwise.
COMMUNITY MEMBER/PETITIONER
A grievance process is initiated by the person who was the direct recipient of the alleged harm and is termed the “petitioner.” It is assumed from the start that a petitioner is sincere in their allegation unless and until the investigation brings up adequate evidence to reasonably indicate otherwise.
Petitioners are typically assumed to be a “community member”: that is, someone who has chosen to participate in a Coru activity such as a ritual event or online conference and has experienced harassment or discrimination from a Coru member. This would also include any former Coru members.
INVESTIGATORS
The investigator acts as a “fact finder” whose primary responsibility is to gather sufficient evidence to the complaint issue(s) which would provide the basis for determining whether the allegation entailed discrimination and/or harassment as defined above. Any officer of the Coru at the time that the grievance is made may act as an investigator.
It is assumed that the Chief will be the default investigator unless there is a conflict of interest.
If the Chief is not the investigator due to conflict of interest, then another officer will be chosen based on consensus among the officers, minus the Chief. Where possible and appropriate, it is desirable that the officer chosen shares a lived experience with the community member, e.g. a gender identity or racial identity.
CONFIDENTIALITY
Community members should be aware that confidentiality cannot be guaranteed because some information must be shared to effectively resolve the situation.
Occasions where confidentiality may not be guaranteed include the investigator’s report to the other officers. As clergy, Coru officers are also mandated reporters under California law; petitioners are encouraged to only disclose as much information as it’s relevant and they feel safe doing so.
What the Coru will not do: share any names, addresses, descriptions, or other personal information about a person or people who have been harmed by one or more Coru members to any person outside of the organization whose participation is not necessary to resolving a grievance (unless legally compelled by an active court order). This is true both during the process and after its resolution.
RETALIATION & CONFRONTATION
Neither the Coru itself nor any active member shall take any action against a petitioner, or a petitioner’s witness or support person, in retaliation for a grievance being made. Retaliatory actions include but are not limited to:
Disclosing identifying information about the petitioner or sensitive information about the allegation to any individuals outside of the Coru;
Intimidating or threatening the petitioner in any way;
Deliberately misrepresenting the character of the petitioner in public in any way which undermines the petitioner’s reputation or ability to participate in shared faith community.
Wherever possible, the respondent named in a grievance process is not permitted to have private communications, verbally or in writing, with the petitioner once the grievance has been made known. Until the grievance has been resolved, any communications between the petitioner and respondent is only permitted through any means which have been explicitly allowed in the action plan.
The respondent to a grievance will be required to sign a non-retaliation agreement. Violation of this agreement will lead to disciplinary action based on the violation of the agreement itself, separate from the truth of the matter being alleged.
SUMMARY OF THE PETITIONER’S PARTICIPATION
For ease of reference, the petitioner’s participation in the process outlined below looks like:
Submitting either a written grievance or verbally requesting a Coru member to file one on the petitioner’s behalf.
Within 7-14 days, the petitioner will be contacted by the investigator with one of two conclusions:
The grievance does not fall under the definitions of harassment or discrimination outlined in this policy and the petitioner will be offered next steps on how to address the matter;
The grievance does fall under this policy and next steps on how the grievance process will move forward will be provided.
If this policy has jurisdiction over the grievance, then the investigator will ask the petitioner to schedule a time for a private interview. It’s preferred that the interview be done live whenever possible (i.e. phone, video, or in-person).
The petitioner will be asked about the incident. They will also be asked about any specifics regarding what they need to feel like they have resolution around the matter.
The petitioner may have an advocate or support person present during the interview.
The investigator will take notes and ask the petitioner to review the notes at the end of the interview to ensure their accuracy.
Within 7-14 days after the interview, the petitioner will be contacted with a proposed action plan and asked to either approve it or offer revisions.
If the petitioner offers revisions, an updated action plan will be shared to the petitioner within 7-14 days for approval.
A petitioner may only offer revisions to an action plan once. This is to avoid overextending the process and ensure timeliness.
If a petitioner does not approve of the updated action plan, then they may choose the first action plan instead or to disengage from the grievance process.
An appointed Coru officer will be responsible for assisting the implementation of the action plan. The grievance process will be considered complete when the action plan has concluded.
A petitioner may choose to retract their grievance or end their participation in the grievance process at any time.
GRIEVANCE PROCESS
The grievance process begins with the petitioner choosing to either:
Submit a written grievance form;
Verbally notify a Coru member of alleged harassment or discrimination.
The Coru member who receives the written or verbal notification will acknowledge receipt of the grievance immediately upon receiving it. If relevant, the member will offer appropriate support or intervention at the time of receiving the grievance.
If the notification is a verbal one, the Coru member will fill out a grievance form with any and all information they have on hand.
The form will be submitted to the Chief, as default investigator, for review. If the Chief has a conflict of interest, then the Chief will pass the matter to the Communications officer. The Communications officer will facilitate a conference with the other officers to appoint an investigator from among themselves instead.
The investigator (whether Chief or another officer) will evaluate the information provided to determine whether or not the allegation falls under the harassment or discrimination guidelines defined above. Depending on the investigator’s conclusion, they will then develop a recommended course of action within 7-14 days of receiving the form.
If the allegation does not fall under the purview of a formal grievance policy, then the investigator will contact the petitioner with an explanation of the investigator’s conclusion and next steps to address the allegation. The nature, severity, and persistence of the misconduct can and shall inform the recommendations made by the investigator.
If the investigator concludes that the allegation falls under the purview of a formal grievance procedure, then the investigator will:
Notify the respondent that a formal complaint has been filed, explain the investigation process, and have them sign a non-retaliation agreement;
Notify the petitioner that the grievance falls under the jurisdiction of a formal process and explain next steps;
Schedule times to meet separately with the petitioner and the respondent for an interview. This interview may be conducted in person, by phone, or through video-conferencing.
When meeting with each party, the investigator will take clear, objective notes on the facts of the case. Each party has the right to review the notes for their own interview to ensure that the notes accurately reflect each party’s perspective.
If relevant, the investigator may conduct interviews with any additional individuals who witnessed or participated in the alleged misconduct. These interviews should follow the same process as the interviews with the primary parties.
Upon completing the interviews, the investigator will review and compare statements of facts, as well as any additional relevant evidence, to determine the truth of the matter. The investigator will clearly document their investigative findings and submit it to the other officers for final review. The investigator must complete and submit their report within seven days of concluding their fact-gathering investigation.
The officers will review the report, discuss appropriate next steps, and approve a plan of action based on majority consensus. Any officers who have a conflict of interest should not participate in the final review of the investigator’s report.
Officers must agree on a plan of action within 7-14 days of receiving the investigator’s report. If the investigator is not the appropriate person to ensure follow-through of the action plan or does not feel adequately prepared for the task, then the officers must appoint an appropriate person to do so.
Next steps may include (but are not required to include or limited to):Suspension or termination of respondent’s Coru membership;
Prohibition of respondent’s participation in any future Coru activities;
Review of Coru policies to address outdated or missing procedures;
Mandated training addressing the conduct in question for the respondent or for Coru as a collective, with the goal of providing actionable information to prevent the harm from happening again.
After finalizing the plan, the investigator will inform the petitioner and the respondent in writing about the outcome of the investigation and next steps, including the name and contact information of the Coru officer who will be responsible for ensuring that the action plan is completed.
If the petitioner is dissatisfied with the action plan, then they may submit their feedback along with any proposed solutions back to the appointed Coru officer. The officer will bring that feedback back to the other officers for further discussion.
If majority consensus agrees, then some or all of the petitioner’s suggestions can be adopted into the action plan.
If majority consensus does not agree, then the action plan will remain unchanged.
The appointed Coru officer will respond to the petitioner detailing the officers’ review of the petitioner’s feedback. At this point, the petitioner has three options:
Continue with the original action plan;
Continue with the updated action plan;
Disengage from the grievance process as a whole.
If the updated action plan is adopted, then the Coru officer will notify the respondent with the updated version. If the petitioner chooses to disengage, the Coru may choose to still follow through on disciplinary measures with the respondent.
Once both parties have been made aware of the final action plan, then the appointed Coru officer is responsible for ensuring that the action plan is followed through in a manner that is both timely but not so rushed as to undermine the effectiveness of the steps involved (e.g. training, counseling).
The grievance process will be considered complete once all steps in the action plan have been taken. There is no time limit on how quickly or how long this process can take.
The appointed Coru officer is responsible for indicating in the record when an action plan has been completed and ‘closing out’ the case. A case is closed out by notifying the respondent and the petitioner (if the petitioner has chosen to continue their participation) in writing and by adding a final update to the case record.
Once a case has been closed, it cannot be reopened. A petitioner may file a new grievance concerning a new allegation of harm.
MAINTAINING RECORDS
All materials pertaining to the investigation, report, and action plan should be kept confidential. Only current Coru officers may have access. A case record should include:
The original grievance form;
The investigator’s notes;
The investigator’s report to the officers;
The action plan;
A copy of the petitioner’s feedback (e.g. a screenshot of an email) regarding the action plan, if applicable;
An updated action plan, if applicable;
The date that the action plan has been completed and a signature (typed or otherwise) from the Coru officer that had been appointed to oversee the action plan’s implementation.
Any and all documents related to a grievance, digital or otherwise, should be kept in a private, confidential location. Only active Coru officers may have access to them. The case record should be kept for a minimum of ten years, after which it may be permanently deleted or disposed of by means which preserve the confidentiality of the petitioner and respondent.
The purpose is to maintain a record of sensitive events where harm has occurred for the protection of all parties involved, as well as to provide background context should any future incidents involving one or more of the parties occur again.
GRIEVANCE FORM
Please fill out this form to the best of your ability. As per our guidelines, whoever may be named in the Grievance form will be asked to sign a non-retaliation agreement while we are reviewing your claim.