Policies

SBA Non-Discrimination Compliance Policy

The Shipley School has received a loan pursuant to the Paycheck Protection Program administered by the Small Business Administration (“SBA”). This policy is intended to demonstrate good faith compliance with the regulations issued by the SBA and by other governmental agencies enforcing the laws that attach to the School due to the School’s receipt of federal financial assistance through the SBA loan.  This policy shall remain in place from the time the School receives the SBA funding until the loan is paid or forgiven. 

School Compliance Officers
The School identifies the following individuals to act as its Compliance Officers under this policy:

Title IX Compliance Officer:                 

Brandon Jacobs
bjacobs@shipleyschool.org
(610) 525-4300 x4189
 
Section 504 Compliance Officer:

Sharron Russell
srussell@shipleyschool.org
(610) 525-4300 x4116 
 
The Compliance Officers shall be responsible for coordinating the School’s effort to meet its responsibilities under this policy. The Compliance Officers will receive and investigate any complaints filed under this policy and make recommendations to Michael G. Turner, the Head of School, for the prompt and equitable resolution of complaints.  The School will provide its Compliance Officers and staff appropriate training on this policy and their obligations hereunder.

Non-discrimination, Anti-harassment, Non-retaliation
The School acknowledges its obligations to prohibit discrimination, harassment, or retaliation on the basis of race, color, national origin, age, sex, disability/handicap, or religion in admission to its educational programs, activities, and services, and in employment opportunities or processes.  Retaliation against an individual for filing a complaint under this policy or participating in the informal or formal resolution is prohibited. 

Academic and Non-Academic Services for Persons with Disabilities
The School remains committed to excellence in educational programming and acknowledges its obligation to ensure that no otherwise qualified individual with a disability shall, solely by reason of his/her disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. This includes both academic and non-academic services, such as counseling, extracurricular services, athletics, transportation, health services, recreational activities, clubs, and other activities.  

The School will also assess its ability to make reasonable accommodations to disabled individuals to permit such persons to participate in and enjoy the benefits of the School’s programs and activities so long as doing so does not fundamentally alter the nature of the School’s program.  Individuals who seek an accommodation should contact Sharron Russell, Section 504 Compliance Officer at (610) 525-4300 x4116 or by email at srussell@shipleyschool.org. 

Employment Obligations for Applicants and Employees with Disabilities
The School acknowledges its obligation under the SBA regulations and laws applicable to recipients of federal financial assistance to prohibit discrimination against any employee or applicant based upon his/her disability.  This obligation extends to all aspects of employment, including the hiring and employment processes.

The School will also assess its ability to make reasonable accommodations to disabled individuals so long as doing so does not create an undue hardship.  Individuals who seek an accommodation should contact Section 504 Compliance Officer Sharron Russell at (610) 525-4300 x4116, or by email at srussell@shipleyschool.org.

Facilities Access
The School acknowledges its obligation under the SBA regulations to operate its programs and activities in existing facilities so they are readily accessible to qualified individuals with disabilities. The location in facilities (or movement of classes, meetings, etc. to other facilities) will be scheduled in a manner that will not knowingly deny a student, employee, parent, or visitor with a disability the opportunity to participate on the same basis as such persons without disabilities. Accommodations may be provided to allow access to educational programming or meetings. 

Complaint Procedure
Who may make a complaint? 
A person (student, parent, employee, or applicant) may use this complaint procedure to report a concern or allegation that s/he is being denied an equal opportunity to access the School’s education programs, activities or services, including employment opportunities. 

Who can a complaint be made to? 
A complaint may be reported to the Compliance Officer, an Administrator, or to a staff member. Any complaint received by an Administrator or staff member shall be promptly reported to a Compliance Officer for handling.  

How do you file a complaint? 
A complaint may be made verbally or in writing. The School has an SBA Complaint Form available for those who choose to use it.  
A complaint may also be filed with the SBA directly by sending a letter to the Administrator, Small Business Administration (SBA), Washington, D.C. 20416.

Or you can file a complaint with the Department of Education’s Office of Civil Rights (OCR). OCR’s electronic complaint form is at the following website: http://www2.ed.gov/about/offices/list/ocr/‌complaintintro.html
You may also email OCR’s Discrimination Complaint Form or your own signed letter to ocr@ed.gov. If you write your own letter, please include the information identified above.

Are there timelines for filing a complaint?
Timelines are flexible, but a person with a complaint should try to report it within thirty (30) calendar days after an alleged discriminatory incident.  If the complaint is filed directly with the SBA or OCR, it must be filed within 180 days of the alleged discriminatory action.

How long will it take to have a complaint handled? 
While the School will try to handle the complaint as expeditiously as possible, there can be unexpected or unforeseen circumstances that cause delay. Complaints involving a handicap/disability and request for accommodation will be promptly referred to a 504 team for handling. Those complaints that require an investigation will be completed within thirty (30) days of the complaint, if possible. Should more time be required, the Compliance Officer will notify the complainant. 

Informal complaint process
This policy provides an individual the option of filing an informal complaint (verbally or in writing), which allows a fuller range of options in facilitating prompt resolution of an issue(s). It is the choice of the individual complaining whether to initially pursue an informal complaint procedure. The Compliance Officer, or his/her designee, shall explore an informal resolution with the complainant, which may involve providing advice to the complainant on how to handle the issue(s) or reviewing this policy with persons involved in the issue. If the matter involves the conduct of another person, an informal resolution could involve a meeting with the complainant and that person provided both individuals agreed. Resolution through this informal procedure will be promptly explored. At any time, the complainant may request to end the informal procedure to move to the formal complaint process.

Formal complaint process
An individual may file a formal complaint (verbally or in writing) under this policy. The complainant may use the SBA Complaint Form that the School can provide or should provide the following information: a statement of the complaint that identifies the issue, provides pertinent facts, identifies those involved, and states what remedy is sought. If complainant does not provide a written statement, the Compliance Officer will prepare a statement for the complainant to review for accuracy after interviewing him/her. 

The Compliance Officer, or his/her designee (“Investigator”) shall begin a formal investigation into a complaint within three (3) business days of receipt. Should the complaint allege another person engaged in discriminatory, harassing, or retaliatory conduct (“respondent”), the Investigator shall notify him/her that a complaint was filed, provide a statement of the nature of the allegations, and provide a copy of this policy and any other applicable school policy. The Investigator shall interview the complainant and any respondent as well as witnesses reasonably believed to have relevant information. The Investigator shall also consider relevant documents submitted by any person interviewed. The respondent may submit a written response to the complaint within seven (7) calendar days of being notified of the complaint. 

At the conclusion of the investigation, the Compliance Officer shall submit the written report of the investigator to Michael G. Turner, the Head of School, along with recommendations as to whether and how this policy was violated and a proposed remedy for the situation.  
The Head of School (or his designee) shall review the Compliance Officer’s report and issue a final decision, or, remand the matter back to the Investigator for further investigation. If remanded, the specific areas or issues to be investigated further shall be identified. Once the investigation is complete to the satisfaction of the Head of School, he shall issue a final written decision as to whether and how this policy was violated as well as any remedial corrective action that will be taken to redress the matter and prevent further violations. Any corrective action must be age-appropriate and timely. The decision of the Head of School shall be final and shall be communicated to the complainant and respondent separately and simultaneously as directed by the Head of School.

Notice of Non-Discrimination
 
Based on receipt of federal financial assistance through a Paycheck Protection Program loan administered through the U.S. Small Business Administration (SBA) under the CARES Act, the School acknowledges its obligation to prohibit discrimination, harassment, or retaliation on the basis of race, color, religion, age, national origin, sex, citizenship status, genetic information, handicap or disability in admissions, access, employment, tuition assistance, educational policies, or other school administered student and employee programs and activities.  Questions regarding the School’s compliance with the application and administration of the School’s nondiscrimination policies should be directed to Brandon Jacobs, Title IX Compliance Officer, 814 Yarrow Street, Bryn Mawr, Pennsylvania 19010, (610) 525-4300 x4189, bjacobs@shipleyschool.orgor Sharron Russell, Section 504 Compliance Officer, (610) 525-4300 x4116, srussell@shipleyschool.org, or to the U.S. Department of Education's Office for Civil Rights (OCR) or to the SBA.  Please refer to the School’s SBA Non-Discrimination Compliance Policy on the School’s website for information on how to file complaints with OCR or the SBA.

This notice will remain in effect until the School has satisfied and paid off the SBA Paycheck Protection Loan.  

Posting Requirements
Loan recipients are required to post the non-discrimination policy and notice on their website at or shortly after the time the loan has been funded.  This notice of non-discrimination shall also be published in:  
(i) Local newspapers;
(ii) Newspapers and magazines operated by such recipient or by student, alumnae, or alumni groups for or in connection with such recipient; and
(iii) Memoranda or other written communications distributed to every student and employee of such recipient.
(iv) Publications.
(1) Each recipient shall prominently include a statement of the non-discrimination policy (by publishing the non-discrimination notice) in each announcement, bulletin, catalog, or application form which it makes available to any potential applicant for admission and for employment or which is otherwise used in connection with the recruitment of students or employees.
(2) A recipient shall not use or distribute a publication of the type described in this paragraph which suggests, by text or illustration, that such recipient treats applicants, students, or employees differently on the basis of sex except as such treatment is permitted Title IX. 

Website Privacy Policy

Use of Links
Throughout our Web pages, we provide links to other servers which may contain information of interest to our constituents. We take no responsibility for, and exercise no control over, the organizations, views, or accuracy of the information contained on other servers.

Creating a text link from your Web site to our site does not require permission. If you have a link you'd like us to consider adding to our Web site, please send an email to webmaster@shipleyschool.org with the subject "Link request."
 
Use of Text and Images

If you would like to publish information that you find on our Web site, please send your request to webmaster@shipleyschool.org. Where text or images are posted on our site with the permission of the original copyright holder, a copyright statement appears at the bottom of the page.

For information about using our logo and images, contact the Director of Communications.
 
Accessibility
We welcome your comments. If you have suggestions on how to make the site more accessible, please contact us at webmaster@shipleyschool.org.
 
Web Site Privacy Policy

We have created this statement to demonstrate our firm commitment to your privacy. We do not collect personally identifying information about you when you visit our site, unless you choose to provide such information to us. Providing such information is strictly voluntary. This policy is your guide to how we will handle information we learn about you from your visit to our Web site.
  • Reading or Downloading
    We collect and store only the following information about you: the name of the domain from which you access the Internet (for example, aol.com, if you are connecting from an America Online account, or princeton.edu if you are connecting from Princeton University's domain), the date and time you access our site, and the Internet address of the Web site from which you linked to our site.
    We use the information we collect to measure the number of visitors to the different sections of our site, and to help us make our site more useful to visitors.
     
  • Online Profile Updates and Donations
    If you complete the Profile update form and share your personally identifying information, this information will be used only to provide you with more targeted content. We may use your contact information to send further information about The Shipley School or to contact you when necessary. You may always opt-out of receiving future mailings; see the "Opt Out" section below.
     
  • Sending us an Email
    You may decide to send us personally identifying information, for example, in an electronic mail message containing a question or comment, or by filling out a Web form that provides us this information. We use personally identifying information from email primarily to respond to your requests. We may forward your email to other employees who are better able to answer your questions. We may also use your email to contact you in the future about our programs that may be of interest.
Questions about our policies
If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact us at webmaster@shipleyschool.org.
The Shipley School is a private, coeducational day school for pre-kindergarten through 12th grade students, located in Bryn Mawr, PA. Through our commitment to educational excellence, we develop within each student a love of learning and a desire for compassionate participation in the world.