Response to GRACE Recommendations
Sexual abuse and assault are growing societal challenges and have come to the forefront in higher education as institutions are coming to grips with the magnitude of the problem among students and grappling with appropriate policies and procedures for preventing sexual assault and responding to those involved. In 2012, Bob Jones University voluntarily undertook an unprecedented review of its policies and procedures for responding to students who reveal they were abused or assaulted.
Introduction 
Sexual abuse and assault are growing societal challenges. They are heinous crimes and perpetrators must be brought to justice by our system of law. We are all awakening to the magnitude of these issues and are more publicly addressing them and the trauma they inflict on victims. Over the last few years, sexual abuse and assault have come to the forefront of thinking in the higher education community as institutions are coming to grips with the magnitude of the problem among students and grappling with appropriate policies and procedures for preventing sexual assault and responding to those involved.
In 2012, Bob Jones University voluntarily undertook an unprecedented review of its policies and procedures for responding to students who reveal they were abused or assaulted, primarily before they enrolled as students. In taking this bold step, we subjected ourselves to potential misunderstanding and criticism, but we did so because appropriately responding to victims is more important than our institutional reputation.
As part of the review, 116 people were interviewed, approximately 40 of whom were abuse/assault survivors. Most of these were former Bob Jones University or Bob Jones Academy students, and the individual experiences they reported spanned nearly 40 years.
The report resulting from the review has assisted the University in improving our total student experience, including our response to victims of sexual abuse/assault. Some initiatives discussed below are a direct response to the recommendations in the GRACE Report; others go well beyond. A few have yet to be initiated.
Background and BJU’s Objectives
BJU’s understanding of sexual abuse/assault counseling and our procedures for counseling victims developed and improved over time as our primary counselor worked to gain knowledge, reading books and articles on the topic as they began to be published in the mid- to late ’80s. Diane Langberg, current chair of the executive board of the American Association of Christian Counselors and GRACE board member, recounts a similar experience. In her 2003 book, “Counseling Survivors of Sexual Abuse,” she said of her own professional training, “Sexual abuse was not ever discussed in graduate school. There were no seminars, workshops or articles available. I learned from my clients.”
In late fall 2011, BJU’s former president, Dr. Stephen Jones, asked the Board of Trustees to form a committee to review our policies and procedures for handling reports of sexual abuse and assault and recommend needed changes or enhancements.
An external committee experienced in serving sexual abuse and sexual assault victims was formed in early 2012, and at their recommendation, in summer 2012, BJU instituted a new Abuse and Neglect Policy, appointed a full-time biblical counselor to support students who have experienced sexual abuse or assault, and began seeking an independent person or organization to perform a more in-depth review.
In November 2012, after consulting with the executive committee of the Board of Trustees, BJU contracted with GRACE to undertake the comprehensive, independent review. While we were unaware of any outstanding issues, BJU initiated this review to achieve two primary objectives:
- To ensure BJU’s policies and procedures for handling reports of sexual abuse/assault comply with every aspect of the law and ensure a loving, scriptural response to those involved.
- To provide BJU an opportunity to communicate with and seek the forgiveness of any former students or other individuals who were not helped with our response when they reported to a BJU representative that they had been abused/assaulted.
In January 2013, both BJU and GRACE promoted a link to a survey where individuals could communicate directly with GRACE. Based on survey responses, GRACE interviewed approximately 40 abuse/assault survivors. They delivered a preliminary report to BJU on Nov. 29, 2014. On Dec. 11, 2014, GRACE issued a public report of its findings during the nearly two-year review.
Throughout the entire process, including the investigation and the reporting of findings, GRACE remained totally independent of BJU.
We undertook this project to continue to improve the ways we minister to our students, particularly those who have suffered sexual abuse or assault. We are thankful for those who participated in this challenging, and in some cases, painful process. We are grateful for what we have learned through the process. We have prayerfully analyzed the information in the report, and while the process and the report are not perfect, some of the findings have given us a better understanding of how we can serve our students more effectively.
BJU’s Approach to the Response
Presidential Advisory Committee
After receiving the report, BJU’s president announced that he would appoint a committee to provide advice and counsel on the recommendations in the report. The advisory committee consisted of a biblical counselor, an executive administrator of a regionally accredited university, a professor of pastoral counseling, a leading attorney in abuse and abuse prevention, a human resources executive and a member of the BJU Board of Trustees.
These individuals requested we keep their names confidential, and we are honoring their request. The committee met with the president and the internal team preparing BJU’s response in February 2015. The committee provided valuable input on the issues illuminated in the report and assisted the executive team in refining initiatives outlined in BJU’s response.
In addition the president solicited input from other individuals, from both inside and outside the University, who are knowledgeable of specific related topics.
BJU’s Core Commitments
BJU’s review of and response to the report are based on the following commitments.
- We are committed to the inerrancy, authority and sufficiency of Scripture and, therefore, measured all decisions and changes within a biblical framework.
- We are committed to ensuring BJU’s policies and procedures for handling reports of sexual abuse/assault reflect best practices; facilitate a loving, compassionate, scripturally based response to reports of sexual abuse and sexual assault; and remain in full compliance with federal and state laws.
- We are committed to providing a place of solace to victims of sexual abuse/assault.
- We are committed to communicating with and seeking the forgiveness of any former students or other individuals who came to us in their time of need and did not experience the loving, comforting environment they deserved.
- We are committed to continue to compassionately serve our student body with care and protection, recognizing the importance of every single individual.
- Finally, we are committed to becoming more effective in developing disciples of Jesus Christ through an improved institutional culture that nurtures the pursuit of Christlikeness in a university setting.
Recognizing the importance of the experience of each individual student, BJU’s commitments are based on Micah 6:8: “He hath shewed thee, O man, what is good; and what doth the Lord require of thee, but to do justly, and to love mercy, and to walk humbly with thy God?”
Response to Victims
Initial Public Apology
After analyzing the preliminary report, President Pettit—on Wednesday, Dec. 10, 2014—publicly apologized to those who were not helped by the University’s response to their reports of abuse.
“On behalf of Bob Jones University, I would like to sincerely and humbly apologize to those who felt they did not receive from us genuine love, compassion, understanding, and support after suffering sexual abuse or assault. We did not live up to your expectations. We failed to uphold and honor our own core values. We are deeply saddened to hear that we added to the pain and suffering. To them, I would say—we have carefully listened to your voice. We take your testimony in this report to our hearts. We intend to thoroughly review every aspect and concern outlined in the investigation and respond appropriately.”
This apology was based on the themes in the report. We feel great sorrow for former students who suffered sexual abuse/assault and did not find help at BJU. We greatly desire to speak directly with those who reported we did not serve them well. More specific apologies to individuals will require our seeing what these individuals see.
Listening to Victims
As stated, we greatly desire direct personal contact with each victim of sexual abuse or assault who was not helped by our response to their disclosure. While we realize months or even years may pass before some survivors are willing to talk with us, the invitation for dialogue is open and will remain open. We sincerely want to better understand their individual experiences. We want to be of assistance to them and to hear their suggestions for improving our response to victims. If former students who were abuse/assault survivors will contact the BJU president’s office, we will arrange a meeting with the president or other university representative with whom the victim will be comfortable speaking.
Degree Completion
We are aware of only one person who left the University without completing a degree following disclosure of abuse. We are willing to assist this abuse/assault survivor to complete her degree at BJU or another institution of her choice. Such assistance would be available by direct request to the president’s office.
Victim Advocate
BJU’s Title IX coordinator already provides students the option of having an advocate and solicits advocates on an as needed basis. No later than the beginning of the 2015-16 academic year, BJU will identify and train a larger pool of individuals—inside and/or outside the University—willing to serve as advocates and clearly define the voluntary role. An advocate’s role will be to encourage and assist the victim without any competing objectives.
File Review
An external attorney licensed in South Carolina who previously served in a prosecutorial role with the U.S. Attorney’s Office and is knowledgeable regarding reporting obligations under South Carolina law conducted a review of our files that we are aware reference sexual abuse/assault. The review did not uncover any instances where the University failed to comply with its reporting obligations.
Sermons/Materials
We have begun reviewing all sermons and materials cited in the report. These materials are being evaluated on the basis of Scriptural accuracy and our developing understanding of the issues associated with sexual abuse and assault. We will remove any that do not reflect sound biblical teaching or are found to be insensitive to abuse or assault victims.
With regard to the writings of Jim Berg, we have reviewed his written material on a wide variety of topics and have found them to be faithful to Scripture. Obviously, as would be expected of any writer, his later works reflect the benefit of ongoing growth in and mastery of his subject matter. Thousands of believers have benefited from his books and hundreds of churches have used his materials with great spiritual profit. His book, Changed into His Image, received a positive review from the late Roy Zuck in Bibliotheca Sacra, the theological journal of Dallas Theological Seminary. His writings have appeared in the Journal of Biblical Counseling and are recommended reading for courses at several Bible colleges and seminaries, including Southeastern Baptist Theological Seminary and Southern Baptist Theological Seminary. We will continue to use these materials in our courses and make them available in our campus store and through BJU Press.
Policies
Policy Updates
In the last two years, the University has completed two rounds of Abuse and Neglect Policy reviews and updates. In 2013 we rewrote our policy document with local legal assistance and in 2014 updated the policy with the assistance of MinistrySafe1.
Based in Fort Worth, Texas, and founded by attorneys Gregory Love and Kimberlee Norris, MinistrySafe provides Sexual Abuse Awareness Training and assists child care entities and organizations in the design and implementation of safety systems which reduce the risk of child sexual abuse. In addition, Greg Love and Kimberlee Norris have a nationwide sexual abuse litigation practice representing victims of sexual abuse across the U.S. The firm also represents a number of ministries, camps, churches, schools and other entities delivering children’s services. Each October, MinistrySafe conducts sexual abuse awareness training at BJU which is required for all students, faculty and staff. They regularly assist with the review and updating of BJU and BJA abuse and neglect policies and have advised Student Life on informing students of the scope of Biblical counseling and BJU executives on the employee/student screening process.
We will continue to work with an organization such as MinistrySafe to assist with an annual review and update of policies related to abuse response and prevention. This review will be done in conjunction with our Title IX coordinator. Our goal will continue to be policies and procedures that ensure a loving, compassionate, scripturally based response to abuse/assault victims and that continue to conform to both South Carolina reporting requirements and Title IX and Clery Act requirements.
BJU policy designates all employees as mandatory reporters of child sexual abuse. This policy exceeds both state and federal legal requirements.
For individuals 18 or older who disclose sexual abuse that occurred before they were 18, federal law prohibits colleges and universities whose students receive federal funds from reporting the abuse without the victim’s consent unless mandated by state law. South Carolina law mandates such reporting if there is reason to believe that there is another child (who is under 18 at the time of the disclosure) or vulnerable adult who has been abused or neglected.
For an adult student at Bob Jones University that discloses an on-campus sexual assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report.
For an adult student at Bob Jones University that discloses an off-campus assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report if the location of the incident falls with the geographical area covered by Clery.
We believe in several instances, the GRACE report did not give appropriate consideration to BJU’s Title IX obligations. Further the report imposed a “moral obligation” to report to legal authorities when such a report would have been a violation of federal law.
Annual policy reviews will occur late spring/early summer to accommodate implementation in the academic year beginning in August.
Policy Accountability
As we review and update the policy in spring 2015, we will add a provision that each employee will annually affirm he/she is following the Abuse and Neglect Policy and has fulfilled all reporting obligations within the last year.
Bob Jones Academy Policies
While Bob Jones Academy employees follow mandatory reporting requirements, the Academy currently has a number of other policies for the Child Development Center, the use of volunteers, etc. With the assistance of MinistrySafe, we are preparing a consolidated student safety policy manual for BJA tailored specifically to ensuring the continued safety of minors. It will incorporate all BJA policies into one manual.
Training and Education
Abuse/Assault Awareness Training
Each October the University works with MinistrySafe to conduct Abuse/Assault Awareness Training which is mandatory for all new university students and all new university or academy employees. After attending the training session, each individual is required to take and pass an online quiz in order to receive a certificate of completion. We have trained approximately 5,000 students, faculty and staff the past two years and will continue this training on an annual basis.
In spring 2015, we will formalize a plan for refresher training, including how frequently faculty and staff will attend the training in person and how frequently they will require refresher training via video. The plan will also specify how soon new hires will be trained.
As a follow-up to this training, with the assistance of MinistrySafe and appropriate academic deans, faculty and staff, existing guidelines are being reviewed and enhanced where appropriate for the following students who work with or come in contact with minors on or off campus:
- Education majors
- Nursing majors
- Premed/predent students
- Ministerial students
- Students who participate in Outreach Ministries
- Students who work in the University’s summer camp program
- Student athletes who conduct sports clinics for minors
- Students whose academic internships may bring them into contact with minors
- Students who participate on BJU Ministry Teams (summer and during academic year)
- Admission recruiters
Guidelines for students who work for Bob Jones Academy during the academic year or during summers are being included in the new BJA policy manual.
Student Training in Academic Programs
A number of courses within our curriculum address sexual abuse/assault prevention and reporting. School of Education—All teacher education candidates receive specific training in multiple courses regarding abuse prevention/reporting throughout their four-year education.
College of Arts and Science—The Division of Nursing addresses the subject in three courses, and all clinical students and faculty, through the Greenville Health System (GHS), complete an annual online hospital orientation that also addresses abuse.
College of Arts and Science—Premed students are trained by GHS prior to their internship course at GHS. No training is provided currently for predent students who intern in private dental practices, and the faculty acknowledges the need to close this gap.
School of Religion—Six ministry courses address various aspects of abuse/assault prevention/reporting relevant to students preparing for ministry. Several classes regarding legal issues in counseling and including one class specifically on child abuse and neglect are taught by our Title IX coordinator. Other courses address civil law as it affects pastors, churches, Christian schools and their ministries; maintaining appropriate relationships while working with youth and in discipleship situations; and the importance of background checks and safeguarding those who work in ministries as well as the individuals they serve.
Curriculum in other appropriate programs will be reviewed and improved as appropriate.
In addition, as part of its annual conference series, in November 2012, BJU’s Seminary sponsored a national conference entitled “Sexual Abuse and the Church,” designed to equip pastors and church leaders to biblically handle problems and issues of abuse. Conference speakers included a number of experts in counseling and/or advocating for victims as well as law enforcement officials. BJU Seminary students and faculty also attended the sessions.
Faculty/Staff Training
To further strengthen compliance with Title IX procedures, in spring 2014, seven BJU faculty and staff were trained by the Association of Title IX Administrators in Milwaukee to investigate instances of sexual harassment and sexual assault using a civil rights investigation model. BJU’s Title IX coordinator calls on these seven to work in teams of two—one man, one woman—to investigate reported instances. These investigators receive annual supplemental training.
During In-Service at the beginning of the 2014-15 academic year, the Title IX coordinator trained all full-time and GA Student Life staff on Title IX reporting requirements and placed an article in the August 2014 issue of the monthly faculty/staff newsletter summarizing reporting requirements for faculty and staff.
BJU’s Title IX coordinator is preparing more comprehensive required training for all faculty and staff on their responsibilities under Title IX regarding reports of sexual harassment and assault and other civil rights violations. This training will be regularly scheduled; the timing and frequency have yet to be determined. A discussion of mandatory reporting of the abuse of minors will be included to further clarify for faculty and staff the difference between sexual abuse and sexual assault and the specific legal reporting requirements for each.
To further assist faculty and staff, by the start of the 2015-16 academic year, BJU will incorporate the best practice used by a number of other higher education institutions of placing a “Red Folder” on the faculty/staff intranet page with detailed, easy-to-follow instructions for reporting sexual abuse, directing a student who has been abused/assaulted to the appropriate resources and helping a student report abuse or assault.
Resident Mentors
The University’s official biblical counselors provide all on-campus counseling related to sexual abuse/assault. Resident mentors, however, are an invaluable resource for nurturing and coaching students as they adapt and face the pressures of college life. To better enable resident mentors to assist students, the University is increasing the time resident mentors are trained at the beginning of each academic year and providing them with more robust training in how to mentor in addition to more training on how to help students with academic-related and other issues students face in their day-to-day college experience.
BJU will also create a site on its intranet to provide resident mentors and student discipleship leaders specific guidance on how to respond to common student issues Such a site will provide information on how to initially respond to and assist a student until the student can obtain help from an experienced counselor.
Abuse Awareness Week
Some of what the report recommends be included in a Sexual Abuse/Assault Awareness Week is included in the annual Sexual Abuse/Assault Awareness training. In addition, we will work with advisors such as MinistrySafe to determine appropriate content, format and speakers—both external and internal—for an Abuse Awareness Week or Life Skills Week to be conducted once every four years.
Board of Trustees Training
An awareness training session on abuse/assault prevention, response and reporting will be conducted with the Board of Trustees at a time scheduled by the Chairman of the Board. Subsequent new board members will receive training as part of their new board member orientation prior to their first board meeting.
Student Experience
Overview
BJU seeks to make disciples of Jesus Christ through a biblically faithful liberal arts educational experience within a decidedly conservative and disciplined environment.
BJU’s senior leadership is currently reviewing student development outcomes and student experience programs designed to foster those outcomes. Areas within student development that are under review include the code of conduct and discipline system, residence hall life, leadership training and development, counseling services, and co-curricular experiences. Appropriate changes will be made as outcomes are clarified and programs are reviewed in light of those outcomes.
Residence Hall Evaluations
In spring 2014, BJU changed the residence hall evaluation process, including how the results factor into the identification of future residence hall leadership. Students complete their self-evaluation online and submit it, not to their peer leaders, but to the residence hall supervisor. As part of their self-evaluation, each student has the opportunity to submit the names of fellow students they look to for leadership and recommend for residence hall leadership positions. In selecting individual students for leadership positions, the residence hall supervisor considers both a student’s self-evaluations and the collective recommendations of other students. A review of student outcomes and the student development program is currently underway, and additional changes to the self-evaluation process may result from that review.
Individuals
We have in place policies and procedures to safeguard our campus from sexual offenders. For security reasons we do not disclose those policies and procedures. As in the past, our Department of Public Safety will involve local law enforcement if necessary.
Counseling
On-Campus Counseling
We believe Scripture is sufficient for addressing and meeting the spiritual needs of individual believers. For this reason, we remain firmly committed to a biblical counseling model as the basis for all of our on-campus counseling. In view of the size of our student population, we will maintain an on-campus biblical counseling function. In this regard, BJU is beginning the process of establishing a student care center staffed by an appropriate number of certified biblical counseling personnel.
If a student selects on-campus biblical counseling, he or she is provided a clear description of biblical counseling and confirms in writing an understanding of the nature and scope of this biblical counseling. At the same time, students will continue to have the option to pursue off-campus counseling from a counselor of their choosing. We recognize there currently may be limits to our ability to deal with certain aspects of trauma present in some cases of sexual abuse/assault. While we will strive to offer as much help as we can in such cases, students have the option to go to agencies and or organizations that at this time may be better equipped and prepared to offer help in their specific situations.
Office of Women’s Counselor
The office of the women’s counselor was separated from offices that deal with student discipline in August 2014.
BJU’s women’s counselor can offer students appropriate confidentiality in line with national norms and practices for biblical counseling. Under Title IX and BJU’s discrimination and harassment policy, all other faculty and staff are responsible employees and thus required to report to the Title IX coordinator any instances of sexual misconduct, including sexual assault.
The women’s counselor currently uses an acknowledgment form explaining biblical counseling which students sign prior to receiving counseling. We’re currently reviewing the acknowledgment form to ensure it is in line with best practices on informed consent.
Biblical Counseling Degree Programs
With the support of the Office of Planning, Research and Assessment, and under the leadership of the vice president for ministerial advancement/dean of the seminary and school of religion as well as the chief academic officer, the Seminary and School of Religion have begun a program review of the undergraduate and graduate biblical counseling programs. Per existing program review protocols, the review includes a team of academically experienced and qualified peer reviewers from other seminaries and Christian colleges. Key areas of the review include program learning outcomes, curriculum, resources, and faculty.
In undertaking this review, our commitment is to a biblical counseling model and our desire is to provide a degree that meets the highest educational standards and enables graduates of the Seminary program to receive certification from a nationally recognized biblical counseling association if they desire.
Personnel
Bob Jones University considers all personnel matters private and handles them internally.
Other
BJU’s response to specific recommendations not included above will be determined in the future.
Questions & Answers
Now that President Pettit has given BJU’s response to the report, what are the next steps for BJU?
BJU has identified a number of ongoing and future initiatives which are part of a comprehensive plan to improve a student’s total experience at BJU. While some of these initiatives are in direct response to the report recommendations, many are independent of the report or recommendations.
Who served on the advisory committee and what input did they have on the final response?
The advisory committee consisted of a biblical counselor, an executive administrator of a regionally accredited university, a professor of pastoral counseling, a leading attorney in abuse and abuse prevention, a human resources executive and a member of the BJU Board of Trustees. These individuals requested we keep their names confidential, and we are honoring their request. The committee met with the president and executive leadership in February 2015. The committee provided valuable, independent input on the issues illuminated in the report and assisted the executive team in refining initiatives outlined in BJU’s response.
In addition the president solicited input from numerous individuals, from both inside and outside the University, who are knowledgeable of specific related topics.
Who at BJU assisted with the response?
The president has driven the University’s efforts with support from members of the executive team.
Through prayerful consideration along with advice and counsel of the advisory group and significant input from the University’s leadership team, the president ultimately is responsible for the final decisions.
On what basis did the president make his decisions?
BJU’s review of and response to the report are based on the following commitments.
- We are committed to the inerrancy, authority and sufficiency of Scripture and, therefore, measured all decisions and changes within a biblical framework.
- We are committed to ensuring BJU’s policies and procedures for handling reports of sexual abuse/assault reflect best practices; facilitate a loving, compassionate, scripturally based response to reports of sexual abuse and sexual assault; and remain in full compliance with federal and state laws.
- We are committed to providing a place of solace to victims of sexual abuse/assault.
- We are committed to communicating with and seeking the forgiveness of any former students or other individuals who came to us in their time of need and did not experience the loving, comforting environment they deserved.
- We are committed to continue to compassionately serve our student body with care and protection, recognizing the importance of every single individual.
- Finally, we are committed to becoming more effective in developing disciples of Jesus Christ through an improved institutional culture that nurtures the pursuit of Christlikeness in a university setting.
Recognizing the importance of the experience of each individual student, BJU’s commitments are based on Micah 6:8: “He hath shewed thee, O man, what is good; and what doth the Lord require of thee, but to do justly, and to love mercy, and to walk humbly with thy God?”
Yes. An outside attorney licensed in South Carolina who previously served in a prosecutorial role with the U.S. Attorney’s Office and is knowledgeable regarding reporting obligations under South Carolina law conducted a review of our files that we are aware reference sexual abuse/assault.
What has Bob Jones University done to heighten awareness of abuse/assault?
Prior to receiving the report, in 2013 and 2014, BJU—through MinistrySafe and Abuse Prevention Systems—proactively provided training sessions for all faculty, staff and students, and will continue to provide sexual abuse awareness training to all students and employees in subsequent years. As part of this process, we are preparing specific guidelines for those who work with minors in a variety of capacities both on and off campus. In addition, we hosted a comprehensive Child Safety Workshop for local church leaders in May 2014.
Have you changed your counseling structure since initiating the review?
Yes. In 2012, the BJU Board of Trustees requested the administration hire a full-time women’s counselor to assist with sexual abuse /assault victims. In addition to our full-time women’s counselor, we have identified and shared with students several off-campus options for counseling in addition to on-campus biblical counseling options.
We remain firmly committed to a biblical counseling model as the basis for all of our on-campus counseling. In view of the size of our student population, we will maintain an on-campus biblical counseling function. In this regard, BJU is beginning the process of establishing a student care center that will include an appropriate number of biblical counseling personnel.
The president acknowledged that some of this fear may have resulted from our culture of placing too much emphasis on policies and not enough emphasis on people. Rules were often more important than relationships. We are committed to removing any barriers students may have to seek help out of fear of potential discipline. We will be reviewing and making appropriate changes to the Code of Conduct and how it is implemented.
In addition, in August 2014, BJU physically separated the office of the women’s counselor from other campus offices that handle student discipline.
We’ve made a number of changes. We have physically separated the sexual abuse/assault counseling function from the Dean of Students, Dean of Men and Dean of Women’s offices. We have employed stricter confidentiality standards. We provide them a description of biblical counseling and each student signs an acknowledgement form prior to counseling. In addition, we inform our students of external options which they may consider better suited to deal with their particular situation.
A few of the initiatives referenced by the president include, but are not limited to:
- Instituting a more formal victim advocate program
- Adding an annual accountability feature to our Abuse and Neglect Policy by which employees confirm compliance
- Developing a new training program for faculty and staff on Title IX and mandatory reporting obligations
- Implementing more robust training for resident mentors on assisting students with a broad range of issues
- Planning abuse/assault awareness training for the Board of Trustees
- Beginning the planning of a new student care center
Does BJU plan to change its Code of Conduct?
The Code of Conduct is being reviewed as part of the broader review of the total student experience. Specific changes have yet to be determined.
We desire to rebuild relationships with former students who came to us in their time of need and did not experience the loving, comforting environment they deserved. We are hopeful they will see through this response that we have heard their voice. We also are hopeful that the report will contribute to opening communication between BJU and those who shared their painful experiences during the review. We desire to meet personally with each one over time, hear individual stories directly and determine a mutual path forward. We ask that as victims are ready to meet with us that they contact the president’s office directly.
We greatly desire to meet and talk personally with each victim of sexual abuse or assault who was not helped by our response to their disclosure. Some may be willing to meet right away; others may need more time. The invitation to meet remains open indefinitely. We sincerely want to better understand their individual experiences. We’re also interested in their suggestions for improving our response to victims. We are asking former students who were abuse/assault survivors to contact the BJU president’s office to arrange a meeting with the president or other university representative with whom the victim will be comfortable speaking.
We will provide a counselor experienced in helping abuse/assault victims to serve as a liaison between the victim and BJU. There is no time limit on our desire to speak with victims. We will meet with them when they are ready.
We have begun reviewing all sermons and materials cited in the report. These materials are being evaluated on the basis of Scriptural accuracy and our developing understanding of the complicated issues associated with sexual abuse and assault. We will remove any that do not reflect sound biblical teaching or are found to be insensitive to abuse or assault victims.
With regard to the writings of Jim Berg, we have reviewed his written material on a wide variety of topics and have found them to be faithful to Scripture. Obviously, as would be expected of any writer, his later works reflect the benefit of ongoing growth in and mastery of his subject matter. Thousands of believers have benefited from his books and hundreds of churches have used his materials with great spiritual profit. His book, Changed into His Image received a positive review from the late Roy Zuck in Bibliotheca Sacra, the theological journal of Dallas Theological Seminary. His writings have appeared in the Journal of Biblical Counseling and are recommended reading for courses at several Bible colleges and seminaries, including Southeastern Baptist Theological Seminary and Southern Baptist Theological Seminary. We will continue to use these materials in our courses and make them available in our campus store and through BJU Press.
We believe Scripture is sufficient for addressing and meeting the spiritual needs of individual believers, and we remain firmly committed to a biblical counseling model as the basis for all of our on-campus counseling. In view of the size of our student population and our firm commitment to providing a biblical counseling model, we will maintain an on-campus biblical counseling function and will continue to counsel abuse/assault victims.
If a student selects on-campus biblical counseling, he or she is provided a clear description of biblical counseling and confirms in writing an understanding of the nature and scope of biblical counseling.
At the same time, students continue to have the option to pursue off-campus counseling from a counselor of their choosing.
What is the Student Care Center?
BJU is initiating planning for a student care center to assist students with a variety of issues and it will include an appropriate number of biblical counseling personnel.
Biblical counseling is based on the belief that the Bible, as God’s inspired and inerrant Word, is a sufficient and reliable guide for people living in a broken world. For a Christian, the Bible is the final authority for faith and practice. Biblical counseling is the process where the Bible, God’s Word, is related individually to a person or persons who are struggling with suffering or sin, so that he or she might genuinely change in the inner person to be pleasing to God and conformed to the likeness of Jesus Christ.
Why does BJU not discuss the information in the cases listed in the report?
Federal privacy laws limit our ability to respond to the information presented in the various cases. These laws include FERPA and Title IX.
We assume that the cases were used to illustrate certain points, and we will consider these points in our efforts to continuously improve our response to reports of sexual abuse and sexual assault.
Did BJU blame victims for sexual abuse and sexual assault?
Victims should never be blamed for abuse or assault. If there has ever been any hint of blame, directly or indirectly, placed on a student who is a survivor of sexual abuse or assault—that was unacceptable. Let us be clear—the fault lies solely with the perpetrators of these horrific crimes.
Did BJU discourage students or others from reporting sexual abuse and assault?
Some reported to GRACE that they were discouraged from reporting. If this occurred, it is unacceptable. In our policies and procedures, we have made it abundantly clear that any child sexual abuse or suspected abuse is to be reported within 24 hours to local law enforcement, and we have made each employee of Bob Jones Academy and BJU a mandatory reporter.
For individuals 18 or older who disclose sexual abuse that occurred before they were 18, federal law prohibits colleges and universities whose students receive federal funds from reporting the abuse without the victim’s consent unless mandated by state law. South Carolina law mandates such reporting if there is reason to believe that there is another child (who is under 18 at the time of the disclosure) or vulnerable adult who has been abused or neglected.
For an adult student at Bob Jones University that discloses an on-campus sexual assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report.
For an adult student at Bob Jones University that discloses an off-campus assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report if the location of the incident falls with the geographical area covered by Clery.
With regard to our current policies, as an educational institution subject to FERPA, Title IX, and the Clery Act, current procedures provide:
- If a member of the faculty/staff of Bob Jones Academy or Bob Jones University has reason to believe a minor has been abused or neglected either on or off campus, he or she must contact local law enforcement authorities to make a mandatory report within 24 hours.
- Any student of Bob Jones University who has reason to believe a minor has been abused or neglected on or off campus must report the incident to local law enforcement within 24 hours.
- For individuals 18 or older who disclose sexual abuse that occurred before they were 18, federal law prohibits colleges and universities whose students receive federal funds from reporting the abuse without the victim’s consent unless mandated by state law. South Carolina law mandates such reporting if there is reason to believe that there is another child (who is under 18 at the time of the disclosure) or vulnerable adult who has been abused or neglected.
- For an adult student at Bob Jones University that discloses an on-campus sexual assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report.
- For an adult student at Bob Jones University that discloses an off-campus assault, the student is encouraged to report to local law enforcement immediately. Institutions of higher education are to provide adult student victims the option to (1) notify proper law enforcement authorities, including on-campus and local police; (2) be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and (3) decline to notify such authorities. In addition, in compliance with Title IX, BJU will initiate an internal investigation and disclose the assault on its annual Clery Report if the location of the incident falls with the geographical area covered by Clery.
Who is considered a mandatory reporter at BJU?
Every employee of BJU and BJA is a mandatory reporter of sexual abuse and has been trained to recognize and report sexual abuse of a minor directly to appropriate local law enforcement agencies. BJU actively encourages current and former students 18 years of age and older to report abuse directly to appropriate local law enforcement agencies, and we will provide them with assistance if they desire.
What is the status of the solicitor’s review of BJU reporting obligations?
We have not received any update from the Circuit Solicitor on the status of his review. His office has reached out through local media and letters to those interviewed for the report to seek additional information.
To further strengthen compliance of Title IX procedures, in spring 2014, seven BJU faculty and staff were trained by the Association of Title IX Administrators in Milwaukee to investigate instances of sexual harassment and sexual assault using a civil rights investigation model. The Title IX coordinator calls on these seven to work in teams of two to investigate reported instances of abuse/assault. These investigators receive annual supplemental training.
During In-Service at the beginning of the 2014-15 academic year, BJU’s Title IX coordinator trained all full-time and GA Student Life staff on Title IX reporting requirements and placed an article in the August 2014 issue of the monthly faculty/staff newsletter summarizing faculty and staff reporting requirements.
BJU’s Title IX coordinator is preparing more comprehensive required training for all faculty and staff on their responsibilities under Title IX regarding reports of sexual harassment and assault and other civil rights violations. The schedule, timing and frequency have yet to be determined. A discussion of mandatory reporting of the abuse of minors will be included to further clarify for faculty and staff the difference between sexual abuse and sexual assault and the specific legal reporting requirements for each.
To further assist faculty and staff, by the start of the 2015-16 academic year, BJU will incorporate the best practice used by a number of higher education institutions of placing a �Red Folder� on the faculty/staff intranet page with detailed, easy-to-follow instructions for reporting sexual abuse, directing a student who has been abused/assaulted to the appropriate resources and helping a student report abuse or assault.
Do any academic programs provide students information on abuse/assault prevention/reporting?
Yes. A number of courses within our curriculum address sexual abuse/assault prevention and reporting.
School of Education—Throughout their four-year education, teacher education candidates receive specific training in multiple courses regarding abuse prevention/reporting throughout their four-year education.
College of Arts and Science—The Division of Nursing addresses the subject in three courses, and all clinical students and faculty, through the Greenville Health System (GHS), complete an annual online hospital orientation that also addresses abuse.
College of Arts and Science—Premed students are trained by GHS prior to their internship course at GHS. No training is provided currently for predent students who intern in private dental practices, and the faculty acknowledges the need to close this gap.
School of Religion—Six ministry courses address various aspects of abuse/assault prevention/reporting relevant to students preparing for ministry. Several classes regarding legal issues in counseling and including one class specifically on child abuse and neglect are taught by BJU’s Title IX coordinator. Other courses address civil law as it affects pastors, churches, Christian schools and their ministries; maintaining appropriate relationships while working with youth and in discipleship situations; and the importance of background checks and safeguarding those who work in ministries as well as the individuals they serve.
Do students, faculty and staff receive abuse/assault awareness training?
Yes. Each October the University works with MinistrySafe to conduct Abuse/Assault Awareness Training which is mandatory for all new university students and all new university or academy employees. After attending the training session, each individual is required to take and pass an online quiz in order to receive a certificate of completion. We have trained approximately 5,000 students, faculty and staff the past two years and will continue this training on an annual basis.
In spring 2015, we will formalize a plan for refresher training, including how frequently faculty and staff will attend the training in person and how frequently they will receive training via video.
What are some of the actions BJU is taking to promote sexual abuse/assault awareness?
BJU will continue to hold and require new students, faculty and staff to attend Sexual Abuse/Assault Awareness training through MinistrySafe. In addition, we will work with advisors such as MinistrySafe to determine appropriate content, format and speakers—both external and internal—for an Abuse Awareness Week or Life Skills Week to be conducted once every four years.
Does BJU provide advocates to victims of abuse/assault?
Yes. BJU’s Title IX coordinator already provides students the option of having an advocate. No later than the beginning of the 2015-16 academic year, BJU will identify and train a larger pool of individuals—inside and/or outside the University—willing to serve as advocates to encourage and assist victims of sexual abuse/assault without any competing objectives.
What are BJU’s confidentiality standards regarding counseling?
BJU’s women’s counselor can offer students appropriate confidentiality in line with national norms and practices for biblical counseling. Under Title IX and BJU’s discrimination and harassment policy, all other faculty and staff are responsible employees and thus required to report to the Title IX coordinator any instances of sexual misconduct, including sexual assault.
The women’s counselor currently uses an acknowledgment form explaining biblical counseling which students sign prior to receiving counseling. We’re currently reviewing the acknowledgment form to ensure it is in line with best practices on informed consent.
What is MinistrySafe and what is their role for BJU?
MinistrySafe, based in Fort Worth, Texas, and founded by attorneys Gregory Love and Kimberlee Norris, provides Sexual Abuse Awareness Training and assists child care entities and organizations in the design and implementation of safety systems which reduce the risk of child sexual abuse.
In addition, Greg Love and Kimberlee Norris have a nationwide sexual abuse litigation practice representing victims of sexual abuse across the U.S. The firm also represents a number of ministries, camps, churches, schools and other entities delivering children’s services. Each October, MinistrySafe conducts sexual abuse awareness training at BJU which is required for all students, faculty and staff. They also assist with policy and procedure updates.
What is BJU doing to improve the total BJU student experience?
BJU is currently reviewing the outcomes we desire for students and the programs designed to foster them. Areas under review include the code of conduct and discipline system, residence hall life, leadership training and development, counseling services and the student’s co-curricular experiences. Changes will be made as appropriate.
Yes. BJU takes the responsibility of safety on our campus very seriously. While there have been a few reports of abuse and assault involving people on campus as reported to law enforcement and on the University’s annual Clery Report, the vast majority of our abuse/assault-related counseling results from students reporting abuse or assault they suffered while they were children or adults living at home.
The campus, including individual buildings, is secured relative to events and time of day and personal safety instruction is available to the student body.
BJU’s Public Safety team employs full-time and part-time officers who are trained and registered through the S.C. Law Enforcement Regulatory Division (SLED). Each officer is registered as a private security officer and has the same authority and arrest powers as a deputy sheriff when they are on campus. BJU’s Department of Public Safety also has several full-time employees who are trained through the S.C. Criminal Justice Academy and are certified Class 1 law enforcement officers and commissioned as State Constables by the Governor’s office.
We have in place policies and procedures to safeguard our campus from sexual offenders. For security reasons, we will not disclose those policies and procedures. As in the past, our Department of Public Safety will involve local law enforcement if necessary.
What additional safety features are available at BJU?
One of the keys to BJU’s excellent record of safety is the personal integrity of the University community and our code of conduct. For example, because alcohol is not permitted at BJU, we generally do not have any problems with alcohol-related incidents. In addition, we have taken a number of proactive steps to ensure that our students are safe and that we are prepared to respond appropriately in case of any emergency. Some of these steps include electronic entry systems on all residence halls and most other campus buildings, routine 24/7 public safety patrols on campus, electronic emergency notification system, and excellent relationships with local law enforcement.
Additionally, BJU provides victims an online resource to report incidents of sexual misconduct, sexual harassment, discrimination or harassment. Victims also have the option to leave a private voice mail message for BJU’s Title IX coordinator.Over the last several years as we’ve updated our Abuse and Neglect Policy, as well as our sexual abuse/assault policies, we’ve notified and communicated with students through the student handbook and our website. Students read the current version of the student handbook and acknowledge it annually.
There’s been a comprehensive effort to update, streamline and simplify policies and procedures and provide an avenue for students to report incidents online or to leave a private voice mail message for BJU’s Title IX coordinator. Further information about policies are available online.
Does Bob Jones University report public safety information to any governmental agency?
Yes. Each year, BJU publishes an annual campus security report in compliance with the Clery Act. The security report includes campus crime statistics, reporting crimes, coordination between law enforcement agencies, fire and medical emergencies, emergency notification, response and evaluation, crime prevention, victim support services, the BJU Policy on Sexual Harassment, other BJU policies and more.
In 2011, BJU reported 9 forcible sexual offenses reported on campus. Can you explain that?
Nine students reported being touched by a single perpetrator in the campus library during regular library hours. The nine students reported the incidents to campus authorities the same day. BJU has a no tolerance policy and immediately facilitated the reporting of the incidents to the Greenville Police Department and offered counseling to the students. The student perpetrator was dismissed. Representatives of the solicitor’s office interviewed the nine students and over the next months resolved the matter through the legal system.
The category under which BJU reported the offenses—forcible sexual offense—includes a wide range of offenses. This does not diminish the gravity of the situation as we are grieved over any kind of sexual misconduct.
How did GRACE proceed with the review process?
Beginning January 10, 2013, GRACE collected surveys on their website from individuals who wanted to submit information to them. Following receipt of the surveys, GRACE reviewed all survey input and identified individuals they wanted to interview. GRACE has also told BJU they asked some others for written statements. In subsequent months, they conducted the interviews and scheduled interviews with some current and former BJU faculty and staff mentioned by the original interviewees as well as other people they thought could provide relevant information. The final report was posted by GRACE on Dec. 11, 2014.
Where may I access the report?
You may access the report at www.netgrace.org.
What led BJU to review its policies and procedures regarding the reporting of sexual abuse?
Sexual abuse and assault are growing societal challenges. We are all awakening to the magnitude of these issues and are more publicly addressing them and the trauma they inflict on victims. Over the last few years, sexual abuse and assault have come to the forefront of thinking in the higher education community as institutions are coming to grips with the magnitude of the problem among students and grappling with appropriate policies and procedures for preventing sexual assault and responding to those involved. In 2012, Bob Jones University voluntarily undertook an unprecedented review of its policies and procedures for responding to students who reveal they were abused or assaulted, primarily before they enrolled as students. In taking this bold step, we subjected ourselves to potential misunderstanding and criticism, but we did so because appropriately responding to victims is more important than our institutional reputation.
No. In 2011, there were increasing national news stories of some institutions of higher learning facing major problems of sexual abuse/assault on campus. These reports led the president of BJU to seek board approval to form a committee to evaluate BJU’s policies and procedures in this area.
In November 2012, after consulting with the executive committee of the Board of Trustees, BJU contracted with GRACE to undertake the comprehensive, independent review. While we were unaware of any outstanding issues, BJU initiated this review to achieve two primary objectives:
- To ensure BJU’s policies and procedures for handling reports of sexual abuse/assault comply with every aspect of the law and ensure a loving, scriptural response to those involved.
- To provide BJU an opportunity to communicate with and seek the forgiveness of any former students or other individuals who were not helped with our response when they reported to a BJU representative that they had been abused/assaulted.
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