Institutional Access and Compliance Office and Title IX and Non-Discrimination

GCU's Commitment to Title IX

At Grand Canyon University, we are committed to maintaining an academic environment that is free from gender or sexual discrimination so members of the GCU community can fully access and benefit from the university's programs and activities. Learn more about the sexual misconduct policies at GCU.

GCU is also committed to upholding Title IX, which prohibits sexual discrimination in education programs that receive federal funding; nearly all colleges and universities benefit from federal funding.

View Title IX Resource Guide

Title IX and Non-Discrimination Policy

Grand Canyon University, while reserving its lawful rights where appropriate to take actions designed to ensure and promote the Christian principles that sustain its mission and heritage, prohibits unlawful discrimination, including any form of harassment and/or retaliation, on the basis of age, disability, national origin, race, color, religion, sex, pregnancy, veteran status or any other classification protected by applicable law, in its employment, admissions policies, educational programs or activities. It is the purpose of the university to pursue the highest of academic standards within a context that celebrates and extends the spiritual and ethical ideals of the Christian faith. This policy also complies with the Title IX requirements related to non-discrimination.

Grand Canyon University adheres to all federal, state and local civil rights laws prohibiting discrimination in employment and education. As a recipient of federal financial assistance for education activities, GCU is required by Title IX of the Education Amendments of 1972 to ensure that all of its education programs and activities do not discriminate on the basis of sex. GCU also prohibits retaliation against any person opposing discrimination or participating in any discrimination investigation or complaint process internal or external to the institution. Sexual harassment, sexual assault, dating and domestic violence and stalking are forms of sex discrimination, which are prohibited under Title IX and by university policy. Harassment or discrimination on the basis of any other classification protected by law is prohibited under university policy. Any member of the campus community, guest or visitor who acts to deny, deprive or limit the educational, employment, residential or social access, opportunities and/or benefits of any member of the GCU community on the basis of sex or other protected class status, is in violation of the Title IX and Non-Discrimination Policy. Any person may report sex discrimination, age, disability, national origin, race, color, religion, sex, pregnancy, veteran status or any other classification protected by applicable law, in person, by mail, by telephone, by video or by email, using the contact information listed for the Title IX Coordinator (below).

View Title IX and Non-Discrimination Policy

For Title IX concerns, contact:

Title IX Coordinator and Deputy Coordinators 

Shanna Milonas, MBA
Vice President of Academic Compliance
Title IX and 504 Coordinator
3300 W. Camelback Road
Phoenix, AZ 85017

Deputy Title IX Coordinator

Kelsey Nelson, MBA
Director of Institutional Access and Compliance Office
Deputy Title IX Coordinator
3300 W. Camelback Road
Phoenix, AZ 85017

Assistant Deputy Title IX Coordinators

For students:

Tim Griffin
Dean of Students

For athletics:

Jamie Boggs
Director of Athletics 

U.S. Department of Education

Office for Civil Rights
Building 400 Maryland Ave., SW
Washington, D.C. 20202
Phone: 800-421-3481
Fax: 202-453-6012
TDD: 800-877-8339

What Is Title IX?

Title IX is a federal mandate that protects students attending educational institutions from sex discrimination. The law says that students cannot be denied participation in any school program solely based on their sex. Take a look at frequently asked questions about Title IX to learn more about this policy.

View Title IX FAQs


View Policy Examples

Claimant: The person who is alleging a violation of the Title IX and Non-Discrimination Policy.

Respondent: The person whose actions are alleged to have violated the Title IX and Non-Discrimination Policy.

Unwelcome conduct, determined by a reasonable person, to be so severe, and pervasive, and, objectively offensive, that it effectively denies a person equal access to the university’s education program or activity. Unwelcomeness is subjective and determined by the Complainant (except when the Complainant is below the age of consent). Severity, pervasiveness and objective offensiveness are evaluated based on the totality of the circumstances from the perspective of a reasonable person in the same or similar circumstances.

An employee of the university conditions the provision of an aid, benefit, or service of the university on an individual’s participation in unwelcome sexual conduct.

  • Sex Offenses, Forcible: Any sexual act directed against another person, without the consent of the Complainant, including instances in which the Complainant is incapable of giving consent.
  • Forcible Rape: Penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the consent of the Complainant.
  • Forcible Sodomy: Oral or anal sexual intercourse with another person that is forcibly committed, and/or against that person’s will (non-consensually), or not forcibly or against the person’s will in instances in which the Complainant is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity.
  • Sexual Assault with an Object: The use of an object or instrument to penetrate, however slightly, the genital or anal opening of the body of another person, forcibly, and/or against that person’s will (non-consensually), or not forcibly or against the person’s will in instances in which the Complainant is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity.
  • Forcible Fondling: The touching of the private body parts of another person (buttocks, groin, breasts), for the purpose of sexual gratification, forcibly, and/or against that person’s will (non-consensually), or not forcibly or against the person’s will in instances in which the Complainant is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity.
  • Sex Offenses, Non-forcible:
    • i) Incest: Non-forcible sexual intercourse, between persons who are related to each other, within the degrees wherein marriage is prohibited by Arizona law.
    • ii) Statutory Rape: Non-forcible sexual intercourse, with a person who is under the statutory age of consent of Arizona.

Dating Violence, defined as: Violence, on the basis of sex, committed by a person, who is in or has been in a social relationship of a romantic or intimate nature with the Complainant.

  • The existence of such a relationship shall be determined based on the Complainant’s statement and with consideration of the length of the relationship, the type of relationship and the frequency of interaction between the persons involved in the relationship.

For the purposes of this definition, dating violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse. Dating violence does not include acts covered under the definition of domestic violence.

Domestic Violence, defined as: Violence, on the basis of sex, committed by a current or former spouse or intimate partner of the Complainant, by a person with whom the Complainant shares a child in common, or by a person who is cohabitating with, or has cohabitated with, the Complainant as a spouse or intimate partner, or by a person similarly situated to a spouse of the Complainant under the domestic or family violence laws of Arizona, or by any other person against an adult or youth Complainant who is protected from that person’s acts under the domestic or family violence laws of Arizona. To categorize an incident as Domestic Violence, the relationship between the Respondent and the Complainant must be more than just two people living together as roommates. The people cohabitating must be current or former spouses or have an intimate relationship.

Engaging in a course of conduct, on the basis of sex, directed at a specific person, that would cause a reasonable person to fear for the person’s safety, or the safety of others; or suffer substantial emotional distress.

For the purposes of this definition, course of conduct means two or more acts, including, but not limited to, acts in which the Respondent directly, indirectly or through third parties, by any action, method, device or means, follows, monitors, observes, surveils, threatens or communicates to or about a person, or interferes with a person’s property. Reasonable person means a reasonable person under similar circumstances and with similar identities to the Complainant. Substantial emotional distress means significant mental suffering or anguish that may but does not necessarily require medical or other professional treatment or counseling.

  • Sexual Exploitation, defined as taking non-consensual or abusive sexual advantage of another for their own benefit or for the benefit of anyone other than the person being exploited and that does not otherwise constitute sexual harassment under this policy. Examples of Sexual Exploitation include but are not limited to:
    • Sexual voyeurism
    • Invasion of sexual privacy
    • Taking pictures, video or audio recording of another in a sexual act or in any other sexually related activity when there is a reasonable expectation of privacy during the activity, without the consent of all involved in the activity or exceeding the boundaries of consent, including the making or posting of revenge pornography
    • Prostituting another person
    • Engaging in sexual activity with another person while knowingly infected with human immunodeficiency virus (HIV) or a sexually transmitted disease (STD) or infection (STI), without informing the other person of the infection
    • Causing or attempting to cause the incapacitation of another person (through alcohol, drugs or any other means) for the purpose of compromising that person’s ability to give consent to sexual activity or for the purpose of making that person vulnerable to non-consensual sexual activity
    • Misappropriation of another person’s identity on apps, websites or other venues designed for dating or sexual connections
    • Forcing a person to take an action against that person’s will by threatening to show, post or share information, video, audio or an image that depicts the person’s nudity or sexual activity
    • Knowingly soliciting a minor for sexual activity
    • Engaging in sex trafficking
    • Creation, possession or dissemination or child pornography
  • Threatening or causing physical harm, extreme verbal, emotional or psychological abuse or other conduct which threatens or endangers the health or safety of any person;
  • Intimidation, defined as implied threats or acts that cause an unreasonable fear of harm in another;
  • Hazing, defined as acts likely to cause physical or psychological harm or social ostracism to any person within the University’s community, when related to the admission, initiation, joining or any other group-affiliation activity;
  • Bullying, defined as: Repeated and/or severe, aggressive behavior, likely to intimidate or intentionally hurt, control or diminish another person, physically and/or mentally.
  • Discrimination, defined as actions that deprive, limit, or deny other members of the community of educational or employment access, benefits, or opportunities, including disparate treatment.

The Law

No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of or be subjected to discrimination under any educational program or activity receiving Federal financial assistance.

Title IX of the Education Amendments of 1972

The Basics of Title IX

  • Title IX is a federal civil right that prohibits sex discrimination in education.
  • It does not apply to female students or athletic programs only. It prohibits sex or gender discrimination in all educational activities or programs.
  • A school must be proactive in ensuring that its campus is free from sexual-based discrimination, harassment or violence.
  • Title IX protects students from facing retaliation, from any source, as a result of involvement with Title IX.
  • Title IX applies to institutions that receive federal financial assistance from ED, including state and local educational agencies.
  • The Office of Civil Rights (OCR) enforces institutions' compliance with Title IX standards.

Forms of Prohibited Discrimination and Harassment

Any participants, beneficiaries, applicants or employees, including students, staff, faculty and visitors who believes they have been subjected to discrimination on the basis of disability (or is unsatisfied with accommodations provided by the University) may file a grievance. The University has both informal and formal mechanisms in place to resolve concerns about disability discrimination, denial of access to services, accommodations required by law or an auxiliary aid they believe they should have received (“disability-related issues”), such as:

  • Disagreements regarding a requested service, accommodation, modification of a university practice or requirement or denial of a request.
  • Inaccessibility of a program or activity.
  • Violation of privacy in the context of a disability.

Discriminatory harassment, based on a protected class, creates a hostile environment when the behavior is sufficiently serious to deny or limit one’s ability to participate in or benefit from the recipient’s education programs and activities. Racial and national origin is a specific form of discriminatory harassment which can take many forms, including slurs, taunts, stereotypes or name-calling, as well as racially motivated physical threats, attacks or other hateful conduct.

Sexual harassment is a specific form of discriminatory harassment prohibited by Title IX and an unlawful discriminatory practice. Acts of sexual harassment may be committed by any person upon any other person, regardless of the sex of those involved. Sexual harassment, as an umbrella category, includes the offenses of sexual harassment, sexual assault, domestic violence, dating violence and stalking.

Information About Sexual Discrimination, Harassment and Violence

Sex Discrimination

Sex discrimination is a form of harassment that involves treating someone unfavorably because of that person's sex. Sex discrimination also can involve treating someone less favorably because of their connection with an organization or group that is generally associated with people of a certain sex, or because of the person's non-conformance with sex stereotypes.

Sexual Harassment

  • 61% of men and 62% of women experience sexual harassment during college.
  • 21-38% of college students experienced sexual harassment perpetuated by faculty/ staff.
  • 39-64.5% of reported cases of sexual harassment were perpetuated by other college students.
  • 37% of female students and 25% of male students reported that the harassment caused them not to want to go to class.
  • At least 35% of college students who experience sexual harassment did not report it to a person of authority.

Sexual Violence

  • It is estimated that the percentage of completed or attempted rape victimization among women in higher educational institutions may be between 20-25% over the course of a college career.
  • It is estimated that between 15-17% of men are sexually assaulted over the course of a college career.
  • Seven out of 10 victims of rape and sexual assault reported knowing the offender.
  • Freshman and sophomores are at greater risk for victimization than juniors or seniors.
  • 34% of students who report being sexually assaulted drop out of college prior to graduation.
  • Only 10% of students who experience sexual assault report it to the police or campus authorities.