October 20, 2019

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Connecticut Releases Sexual Harassment Prevention Training Guidance

The Connecticut Commission on Human Rights and Opportunities (CHRO) has released sexual harassment prevention training in accordance with the Time’s Up Act.

The Act requires employers of all sizes to provide sexual harassment training to supervisors by October 1, 2020 (or within six months of hire, after that date). Employers with at least three employees must provide this training to all other employees, not only supervisors, also by October 1, 2020 (or within six months of hire, after that date).

The CHRO also has offered additional guidance on implementing the new law.

(For details of the Act, see our article, Connecticut Expands Harassment Training and Posting Obligations for Employers.)

The new guidance makes clear that the scope of the Act is intended to reach any employer that employs any individual in Connecticut, provided it also employs at least three employees in total, regardless of location. In other words, an employer with only one employee in Connecticut and at least two employees in other states must comply with the Act’s notification and training requirements.

While the Act was silent on whether the training requirements would be applied to current employees, the CHRO has taken the position that current employees must complete the required training within one year, or by October 1, 2020. The Act requires that all new employees complete training within six months of their start date.

Most employers will be required to supplement their sexual harassment policies and distribute them in the manner required by the statute, as well as offer training to their employees. The CHRO has developed free training and posters that may be distributed. However, as expected, the free training is purposefully generic — providing identical training to management and subordinate employees — and addresses public accommodation and housing discrimination issues (which would not apply to most employers). More important, to the extent that an employer has its own process for receiving and investigating complaints, the free training cannot address that. Rather, it directs the complainant, generally, to report the claim to a supervisor or seek additional assistance from the CHRO directly (which may involve encouraging an employee to file a complaint with the CHRO).

Jackson Lewis P.C. © 2019

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About this Author

Tanya Bovee, employment law compliance attorney, employment lawyer, disability accommodation, Jackson Lewis, Hartford law firm
Office Managing Principal

Tanya A. Bovée is the Office Managing Principal of the Hartford, Connecticut, office of Jackson Lewis P.C.

Ms. Bovée routinely advises and provides management training on all aspects of employment law compliance, employment disputes and personnel matters such as hiring, firing, performance management, internal investigations, and disability accommodation. She also has an active litigation practice, defending employers from federal and state claims. Ms. Bovée also defends employers in OFCCP compliance reviews and oversees...

860-522-0404
Margaret Strange, Jackson Lewis, alternative billing arrangement attorney, employment litigation lawyer, EEOC law, sex discrimination legal counsel
Principal

Margaret (Peggy) J. Strange is a Principal in the Hartford, Connecticut, office of Jackson Lewis P.C. She is also the firm’s National Client Practice Leader.

Ms. Strange joined Jackson Lewis in 1996. She has a broad area of practice and experience within the firm. Ms. Strange manages national, regional and local client relationships, looking for new and innovative ways to add value and build strategic partnerships with clients with a focus on predictability, strategy and alternative billing arrangements.

She also has an active litigation practice that covers the spectrum of employment litigation, including state and federal claims. Her experience includes both suits by private parties and by the Equal Employment Opportunity Commission (EEOC). She has handled cases involving claims of race, age, disability, and sex discrimination, as well as sexual harassment, retaliatory discharge, and wage and hour. She has successfully tried cases in state and federal court and prevailed in appeals before the Second Circuit Court of Appeals and Connecticut Appellate Court.

860-331-1554
Of Counsel

Russell N. Jarem is Of Counsel in the Hartford, Connecticut, office of Jackson Lewis P.C. His practice focuses on representing employers in workplace law matters, including preventive advice and counseling.

Mr. Jarem regularly advises and represents employers in a broad range of employment law matters, including litigation under state and federal anti-discrimination statutes in a variety of forums, including state and federal courts, the Department of Labor, the Connecticut Commission on Human Rights and Opportunities, and the Equal Employment Opportunities...

860-522-0404