ALERT! Connecticut Sexual Harassment Training Guidance Released

ALERT! Connecticut Sexual Harassment Training Guidance Released

The Facts

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As of October 1, 2020, in accordance with the state’s Time’s Up Act, employers of all sizes in Connecticut must provide sexual harassment training to all supervisors.  Employers with three or more employees must provide sexual harassment prevention training to all employees, including supervisors and non-supervisors. If an employee is hired after October 1, 2020, they must be trained within six months of hire.

The Connecticut Commission on Human Rights and Opportunities (CHRO) has recently released guidance related to the implementation of training within the workplace.

The CHRO guidance is explicit in its scope that employers with three employees, anywhere, even if only one employee is located in Connecticut, is subject to the law and must provide Connecticut-compliant training to that employee.

Although as drafted, the Act was silent related to whether or not current employees would be subjected to the training requirement, the CHRO guidance instructs that current employees must complete the training within one year, or by October 1, 2020.

Within the Act, most employers must incorporate the new requirements into their policies and posters.  Although a free training has been developed by the CHRO, as with other states’ free training offerings, the content is purposefully generic and lacks the nuances appropriate for supervisors versus non-supervisors, among others.  The training also topically covers housing discrimination and public accommodations, which will not apply to all employers.

Perhaps most significantly, the training lacks the customization to include internal reporting mechanisms for employees with harassment-related concerns or issues and only provides information related to reporting to the CHRO.

Action Items

Employers with at least one employee in Connecticut are subject to supervisor training requirements and those with at least 3 employees total need to provide training to all Connecticut employees.

Employers should:

  • Prepare for the October 1, 2020 deadline by including Connecticut in the organizations compliance training plan.
  • Confirm that policies and posters are up-to-date.
  • Identify a scalable method for implementing annual training with required content.
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