New State Workplace Harassment Prevention Training Obligations
As part of the state’s new workplace harassment prevention training mandate, the Connecticut Commission on Human Rights and Opportunities is preparing online training materials available free to employers.
Lawmakers expanded the training mandate earlier this year when they approved a sweeping pair of bills.
Employers may check the CHRO website to determine the status of the commission’s work in preparing online harassment prevention training materials as required by the revised law.
CBIA HR counsel Mark Soycher said he believes training will be “portable”—meaning training at one workplace will be accepted at another providing it meets the law’s schedule requirements and covers issues specified in the CHRO posting and training regulations.
To identify the training status of an applicant or new hire, employers should ask a standard question on whether applicants have completed the state-required training, Soycher said.
If so, the applicant should be able to say when, where, and produce a certificate of completion.
An employer may, nonetheless, have a new hire attend another session sooner than required to be consistent with the company’s workplace environment.
The employer can establish the minimum compliance for the present, and identify those who need to attend an upcoming session.
Besides changes to the CHRO complaint process, the legislation establishes new requirements for sexual harassment prevention training and education, effective Oct. 1, 2019:
- Employers must separately notify new employees within three months of hiring about the illegality of sexual harassment and remedies available to victims. This new notification may be satisfied by giving employees a copy of, or a link to, the CHRO designated harassment poster, or comparable information such as a company policy via email, text, in writing, or by posting it on the company website.
- Employers have until Oct. 1, 2020 to provide two hours of harassment prevention training for all employees hired before Oct. 1, 2019. Supervisors who have had training since Oct. 1, 2018 are not required to attend.
- Employees hired on or after Oct. 1, 2019 must complete the training within six months of hire.
- Employers with fewer than three employees must provide two hours of training and education to all existing supervisory employees by Oct. 1, 2020, or within six months to new supervisory employees.
- Employers must provide periodic supplemental training not less than every 10 years.
- The existing 180-day deadline for filing harassment complaints is extended to 300 days after the triggering incident for complaints arising on or after Oct. 1, 2019.
CHRO Training Materials
CHRO executive director Tanya Hughes and senior attorney Cheryl Sharpe recently updated the status of the commission’s online training offerings:
- CHRO training materials will be free and available on the CHRO website by the Oct. 1 deadline.
- CHRO will periodically present this training as a live webinar, but the training module will also be posted online for viewing at any time.
- Content is the same for supervisors and employees, and will run two hours, divided into four segments, so people will be able to complete the training in smaller sessions if desired.
- Content will consist of several video vignettes of hypothetical scenarios, supplemented with Powerpoint slides.
- CHRO staff will respond to email questions in real time in the live sessions, and within 48 hours for those viewing the recorded materials online.
- Training will be available via remote, mobile devices, cell phones, tablets, and laptop or desktop computers.
- Attendees completing the training can download and print an attendance certificate so management can document compliance.
We expect that current CHRO posting and training regulations will be revised to reflect these expanded obligations and to:
- Require all companies to train, not just those with 50 or more employees.
- Require all employees to be trained, not just supervisors.
- Mandate refresher sessions every 10 years rather than the currently recommended three years.
What’s likely to remain are the lists of required and recommended content for a compliant training session.
Any outside training presentation that includes such content would be sufficient to meet the law’s requirements.
EXPLORE BY CATEGORY
Stay Connected with CBIA News Digests
The latest news and information delivered directly to your inbox.