Sexual Allegations Unit (SAU) Intake and Investigation Process
The OIG Sexual Allegations Unit is the only independent investigative body in the nation with jurisdiction over a broad range of sexual misconduct complaints and related allegations involving K-12 school-based staff and students. This includes allegations of inappropriate behaviors that are not implicitly sexual in nature, such as texting with students, giving gifts to students, or other conduct that makes students uncomfortable and violates the professional boundaries mandated by Chicago Public Schools. OIG refers to these allegations in aggregate as “sexual misconduct.”
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Complaint
The OIG Sexual Allegations Unit receives complaints about potential adult-to-student sexual misconduct from designated Title IX School Representatives, school administrators, network administrators, the Office of Student Protections (OSP) and communications sent directly to the OIG.
Anyone may make a complaint to the SAU. Students, parents, guardians and members of the public may choose to file complaints anonymously, though that can impact whether a full investigation is opened. Complainants are encouraged to provide as much detail as possible, including contact information for follow-up conversations. Complaints may be filed via online form, or by contacting the OIG by telephone, email or regular mail. |
Intake
Complaints are reviewed by OIG Sexual Allegations Unit staff. As part of this initial intake process, the OIG collects additional information concerning the allegation(s), including from school administration and/or the complainant, and ensures the alleged misconduct fits within the SAU’s jurisdiction.1
Depending on the severity of the allegations, if there is a potential threat to student safety, information is shared with CPS and/or charter network leadership who determine whether an alleged perpetrator should be removed from CPS pending further investigation. |
Assessment and Referral
All complaints within the OIG Sexual Allegations Unit’s jurisdiction are assigned to either an SAU investigator (see “Investigation”) or an investigative specialist, if the allegation is vague or ambiguous.
Complaints assigned to investigative specialists undergo an initial assessment to better understand the alleged misconduct and determine appropriate next steps. This often includes interviewing complainant(s) and/or mandated reporter(s), conducting background research to identify any prior concerns, and reviewing any available electronic or physical evidence. At the conclusion of this assessment, each complaint that clearly articulates potential misconduct is either assigned to an SAU investigator or referred to another CPS department, if it is not within the OIG’s jurisdiction.2 |
Investigation
Complaints that articulate a clear concern about potential adult-on-student sexual misconduct or grooming are assigned to a trained OIG Sexual Allegations Unit investigator to conduct a thorough and impartial investigation that respects the rights of alleged victim(s) and subject(s).
Each investigation is tailored to the allegations and evidence. The length of an investigation is case-specific and depends on many factors, including: the amount of physical and/or electronic evidence to be collected or subpoenaed; investigative leads that exist at the outset (e.g. anonymous allegations); the number of victims, subjects and witnesses to interview and their cooperation, including the responsiveness of students’ parents/guardians; and whether the police and/or the Illinois Department of Children and Family Services is also involved. In cases involving active CPS students, OSP is tasked with coordinating appropriate outreach and supports. Complainants and Respondents will be notified if allegations meet the criteria of the Title IX Regulations. These investigations often involve the same fact-finding processes as non-Title IX investigations, but they entail specific procedural steps mandated by those regulations. Periodic updates are provided to the parties and complainants during active investigations. However, due to the sensitivity of information shared with the OIG during investigations of sexual misconduct and to protect the integrity of investigations, limited information can be communicated. For more information on Sexual Allegations Unit investigations, see the OIG Fiscal Year 2022 Annual Report pages 32-39. |
Final Report
At the completion of an investigation, OIG Sexual Allegations Unit staff and attorneys review all available evidence and compile a final report summarizing the OIG’s findings.3
If the report substantiates that a violation of CPS policy(ies) occurred, the report is shared with the CPS Board of Education and designated District and/or charter school leaders as required, so that they can determine what action should be taken (disciplinary measures, termination of employment, referral to law enforcement etc). If a report indicates that the allegation(s) is unsubstantiated, it is also shared with District and/or charter school leaders as required. The names of alleged perpetrators and victims are never included in public-facing reports (such as the OIG’s quarterly and annual reports); however, they are included in reports shared with District and school leaders as required by CPS policy, and can be subpoenaed as part of a court proceeding or criminal investigation. |
1 The complaint must clearly articulate an allegation of sexual misconduct or grooming by a CPS-affiliated adult, including employees, contractors, vendors, and charter schools, where the victim is a CPS student and/or a minor. For more information on the types of behavior that fall under sexual misconduct, see CPS rules on Reporting of Child Abuse, Neglect and Inappropriate Relations Between Adults and Students.
2 Complaints may be referred to another CPS department (often OSP, the Law Department, or the Charter network) for a variety of reasons, including that the allegation does not fall within the SAU’s jurisdiction and should be addressed by another department, or the alleged misconduct is not clearly sexual in nature and can be more efficiently addressed with training in lieu of a full investigation.
3 The OIG Sexual Allegations Unit works under a preponderance of the evidence standard and uses its administrative and statutory authority to pursue information and evidence of CPS policy violations. As a result, the OIG often continues its investigation after law enforcement, working under a higher burden of proof, has suspended or closed its investigation.
2 Complaints may be referred to another CPS department (often OSP, the Law Department, or the Charter network) for a variety of reasons, including that the allegation does not fall within the SAU’s jurisdiction and should be addressed by another department, or the alleged misconduct is not clearly sexual in nature and can be more efficiently addressed with training in lieu of a full investigation.
3 The OIG Sexual Allegations Unit works under a preponderance of the evidence standard and uses its administrative and statutory authority to pursue information and evidence of CPS policy violations. As a result, the OIG often continues its investigation after law enforcement, working under a higher burden of proof, has suspended or closed its investigation.