# H O L L A N D   C O L L E G E

HEALTH, SAFETY &amp; SECURITY HARASSMENT &amp; DISCRIMINATION

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[Open original PDF →](https://sam.hollandcollege.com/shared/QMS/Policy/30/AR-30-01-1.pdf)

Referenced from: [Sexual Violence Support](/pages/student-experience/index-html-13/)

## Document text

## H O L L A N D   C O L L E G E

## ADMINISTRATIVE REGULATION

Category:

HEALTH, SAFETY &amp; SECURITY HARASSMENT &amp; DISCRIMINATION

Topic:

Code:

30-01-1

Effective Date:

October 17, 2025

Revision:  SEVEN

Approved by:

Sandy MacDonald, President &amp; CEO of Holland College

## 1. PURPOSE:

- 1.1 All members of the Holland College Community have a right to work and study in an environment that is free from any form of harassment and discrimination. The purpose of this regulation is to make clear Holland College's commitment to addressing harassment and discrimination in its community through support, awareness, education, training and prevention programs, and the appropriate handling of disclosures and reports of incidents of harassment and discrimination. We are also committed to the dignity, respect, and equitable treatment of all College Community members.

## 2. SCOPE:

- 2.1 All complaints of harassment and discrimination as defined in the 'Definitions' section of this process, that occur on Holland College premises or during any College-related activities.
- 2.2 This regulation applies to all members of the College community including: all employees, Board and Foundation members, students, contractors, suppliers of services, individuals who are directly connected to any College initiatives, volunteers, and visitors.
- 2.3 This regulation covers incidents that occur both on and off College premises, in both real and virtual environments, which affect the College working and/or learning environment. Incidents occurring off campus which have no likelihood of impact on the work/study environment are to be pursued through the PEI Human Rights Commission or any other relevant legislation but will not be dealt with under this regulation.

3. RELATED POLICIES, FORMS &amp; DOCUMENTS
2. 3.1 Board Policy 30-01 -Respectful Learning and Work Environment
3. 3.2 Board Policy 30-02 -Sexual Violence Policy
4. 3.3 Board Policy 20-12 -Confidentiality and Reporting of Confidential Information
5. 3.4 Board Regulation 30-02-1 -Sexual Violence Protocol
6. 3.5 Administrative Regulation 30-04-3 -Crisis Management
7. 3.6 Quality Form 003.pdf Complaint Form
8. 3.7 Quality Form 014.docx -Request for Procedural Review
9. 3.8 Quality Form 016.pdf (016.docx) -Sexual Incident Report Form
10. 3.9 P.E.I. Human Rights Act (PEI Human Rights Commission)
11. 3.10 Occupational Health and Safety Act Workplace Harassment Regulations
12. 3.11 Post-secondary Institutions Sexual Violence Policies Act
13. 3.12 Holland College Counselling Services
14. 3.13 Promoting a Respectful and Working Environment
15. 3.14 Holland College Employee Assistance Program  through GreenShield Link to brochure (access in SAM)
4. DEFINITIONS:
17. 4.1 College-Related Activity: The College defines College-Related Activity as any activity that occurs:
- a) as a part of a College program/course;
- b) as a part of other College training events;
- c) as a part of any recreational or social activity sanctioned by the College;
- d) as a part of any other business function of the College; and/or
- e) in or on any premises of, or occupied by, or controlled by the College or where any event sanctioned by the College is being held.

The above apply whether such activities occur on College premises or elsewhere. For the avoidance of doubt, all activities occurring in a residence owned, leased/rented, or controlled in any way, by the College, shall constitute a College-Related Activity.

© Holland College, 2025

- 4.2 College Staff Member : Any employee, including but not limited to all academic employees, support staff, administrators, individuals on secondment to the College, individuals under a Personal Service Contract, and any other individuals in the employ of College, or coach of the College.
- 4.3 Complainant: A member of the Holland College community who, in accordance with this regulation and associated policy, has made a complaint of harassment and/or discrimination.
- 4.4 Discrimination : The College defines discrimination to include any action to limit an individual's or group's access to employment, education, training, goods, services, facilities, activities, contracts, accommodation or membership in a voluntary or trade association based on any of the protected grounds set out in College Policy 3001 and the Prince Edward Island Human Rights Act. Discriminatory action often takes the form of unfavourable differential treatment of one individual by another or the exclusion or restriction of individuals or groups, or harassment of an individual or group.
- 4.5 Harassment : Holland College expressly adopts the definition of harassment articulated by the PEI Occupational Health and Safety Act Workplace Harassment Regulations, i.e. any inappropriate conduct, comment, display, action or gesture or any bullying that the person responsible for the conduct, comment, display, action or gesture or the bullying knows, or ought reasonably to know, could have a harmful effect on a worker's psychological or physical health or safety, and includes conduct that is based on any personal characteristics such as, but not limited to, race, creed, religion, colour, sex, sexual orientation, marital status, family status, disability, physical size or weight, age, nationality, ancestry or place of origin, gender identity or pregnancy.

Sexual Harassment: (sexual harassment is a form of sexual violence and is covered under BR-30-02-1 -Sexual Violence Protocol)

- 4.6 Managerial Responsibility : Personal harassment does not include appropriate managerial direction, delegation, performance management or attendance management.
- 4.7 A No Contact Agreement (NCA) is a mutual agreement between individuals who voluntarily affirm that they will not have direct contact with each other or make indirect contact through third parties. An NCA does not constitute a finding of responsibility for violating College policy, nor does it preclude the possibility of future review of any past interactions. Following discussion and agreement to enter into the NCA, the individuals will receive a letter confirming

- the terms of the agreement. In the event that any of the parties decline to enter into a requested NCA, the College may elect to review the matter to determine whether a No Contact Order is warranted.
- 4.8 No Contact Order: which may include restrictions for specific classes, other academic/non-academic activities, or attendance at specific meetings or events; direct or indirect contact (including but not limited to in person, by phone, email, text, social media, through a third party etc.) with a specific individual or group of individuals. An individual may submit a written appeal of the Order to the Vice President of Corporate Services. The decision rendered by the Vice President shall be considered final and binding.
- 4.9 Respondent: The person who the complainant is alleging committed an act of harassment and/or discrimination.

## 5. RESPONSIBILITIES:

- 5.1 President &amp; CEO: for overall operation of the regulation. In the event that any College Staff Member or appointee (including an appointee retained by or, or on behalf of the College for a certain purpose) who has been assigned a responsibility or role under the regulation cannot act, for whatever reason, the President shall appoint another College Staff Member or appointee (including an appointee retained by or, or on behalf of the College for a certain purpose) to assume their responsibility or role for such period or with respect to such complaints as the President deems advisable.
- 5.2 Vice President Corporate Services, (VP-CS):
- a) for arranging the investigation of the complaint;
- b) for the rendering of a decision, where one is required;
- c) for the imposition of sanctions, as required; and
- d) for ensuring that the Complainant and/or the Respondent, with respect to a complaint, when they are an employee of the College, are advised of the availability of College Employee Assistance Program (EAP) or other external assistance programs.
- 5.3 The Assigned Member of College Management: a Senior Leader of the College, or a designate (including a designate chosen from outside the College Community) chosen by the President &amp; CEO, who will receive and review any requests for a Procedural Review that may result from the Report. Referred to in this process as AMCM (referred to in this process as AMCM).

- 5.4 Management : Management, which includes members of the Management Executive Committee and Senior Leadership Group, are responsible to:
- a) communicate to all members of the College community the College's policy documents regarding a respectful learning and work environment;
- b) monitor the implementation and effectiveness of College policy regarding a respectful learning and work environment and make recommendations as necessary;
- c) The President &amp; CEO has delegated responsibility for overseeing the implementation of these Regulations and the related procedure to the VP-CS.
- 5.5 Investigator: for conducting the investigation into the allegations contained in the complaint and providing an investigation report summarizing the facts collected through the investigation process to the VP-CS.
- 5.6 College Representative : to speak with the Respondent when a complaint under this protocol is initiated. The College Representative shall be a member of the College's Quality Office or Human Resources Department.  The College Representative shall not be a support person to the Complainant, Survivor, or Respondent.
- 5.8 Holland College Employees: Each member of the College community has a responsibility to foster a climate of understanding and mutual respect for the dignity and rights of each individual in all areas of the learning and working environment. This includes providing fair treatment, being inclusive and not bullying, harassing or discriminating.

We all share the responsibility to treat each other, and those who interact with the College, with civility and respect. Every member of the College community has the responsibility to uphold our values and to understand the impact of their behaviour. Members of the community are expected to collaboratively resolve concerns, maintain effective relationships, and contribute to a positive, inclusive community culture.

Community members must consider how social identity, culture, values, and beliefs impact perceptions of what is civil and respectful behaviour. Perceptions can also vary by place, time and context. While factors such as identity may influence perception of behaviour, we will consider the impact of the behaviour and respond to concerns in an effective, inclusive and equitable way.

## 6. PROCESS :

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This symbol identifies an Inherent Quality Concern (IQCcrn). An IQCcrn is a point in a process where a failure to complete a step creates the opportunity for a problem to occur. Outside of correctly completing the process step, no other action is required. The act of completing that step and sometimes subsequent steps is essentially managing a potential risk. See Risk Management of the Complaint.

## GENERAL

- 6.1 This process covers the receiving and investigating of incidents involving discrimination and/or harassment (excluding sexual harassment, which is covered in BR-30-02-1).

Please note: The College reserves the right to determine the classification of a particular incident and how it will be investigated. Use of a form to report an incident does not pre-determine the College's response.

- 6.2 Incidents which occur on College premises or as part of a CollegeRelated Activity, that are considered to be criminal in nature should be reported to the appropriate police agency and must be reported to the Vice President Corporate Services (VP-CS).
- 6.3 With the exception of sexual violence, all other violent incidents relating to the College must be reported by completing a QF184. The completed form is forwarded to the Director of Facilities. If the survivor or others are unwilling to complete the form, the Director of Facilities will complete a QF184 (Holland College Violent Incident Report). Any investigation of such incidents will proceed in cooperation with the investigating police agency.
- 6.4 This process does not affect an individual's right to file a complaint with the PEI Human Rights Commission, or to use the grievance process of any relevant collective agreement, or to proceed in any other manner determined to be appropriate by the complainant.
- 6.5 The Holland College complaint process must begin no later than twelve (12) months from the date of the most recent alleged incident, and not later than twelve (12) months after a student completes or leaves a program or an employee ceases employment with the College.
- 6.6 Any employee, student or other person associated with College operations may register a formal complaint when an actual or perceived condition of harassment or discrimination is experienced.
- 6.7 Where a disclosure or a formal complaint is brought forward in which the individual named as the Respondent is a person in a position identified in this policy as being responsible for the

- implementation or part or all of this policy or its related procedures, the College shall appoint another individual.
- 6.8 If a person in a position that is identified in this policy has a real or perceived conflict of interest in a particular matter, or there is a reasonable apprehension of bias, then that individual will not continue their involvement in the matter and there will be another person appointed to act in that role.

## 7. CONFIDENTIALITY:

- 7.1 Maximum confidentiality is required so that those who have experienced harassment and/or discrimination may feel free to come forward and their individual integrity may be protected throughout the process.
- 7.2 The obligation to keep information confidential does not prevent a person from pursuing counselling, professional health services, legal advice and/or other support services, including personal support networks for either the Complainant or Respondent.
- 7.3 To protect the interests of the Complainant, Respondent and any others who may report incidents of harassment or discrimination, the name of the Complainant, the name of Respondent, the name of the person who reports such an incident, and the circumstances related to the complaint or report will be kept confidential except where disclosure is required by law, or is necessary for the purposes of investigating the complaint or report, taking disciplinary measures in relation thereto, or reporting the incident to the appropriate authorities.

All records of complaints, including contents of meetings, interviews, results of investigations and other relevant material will be kept confidential in accordance with the Freedom of Information and Protection of Privacy Act and the Personal Health Information Protection Act except where disclosure is required by law, or is necessary for the purposes of investigating the complaint or reporting the incident to the appropriate legal authorities.

## 8. FUNDAMENTAL PRINCIPLES:

- 8.1 In establishing Regulations and Procedures for dealing with allegations of harassment or other discriminatory treatment, the College is guided by the following principles:
- a) Holland College is a diverse community, and we recognize that any response would need to reflect an intersectional lens if gender-based harassment and discrimination is compounded by other potential vulnerabilities including but not limited to sexual orientation, gender identity, gender expression,

- indigeneity race/ethnicity, religion, disability or age. Holland College recognizes that each situation might look different based on lived experience.
- b) Every employee, student, and every person engaged in employment, education, or College-related activities, is entitled to be free of all forms of harassment and discrimination.
- c) The College will make every reasonable effort to ensure that no employee, no student, and no person engaged in Collegerelated activities is subject to any form of harassment or discrimination.
- d) The College will take such disciplinary or other measures as it considers appropriate against any employee, student, or other person engaged in College-related activities who subjects any employee or student of the College, or any person engaged in College-related activities to any form of harassment or discrimination, or who threatens or carries out any reprisal against any person who may or has made a complaint under this regulation, or who has or may participate in any aspect of the complaint process.
- e) Any employee, student, or other person engaged in Collegerelated activities has recourse to the alleviating provisions of these regulations, the P.E.I. Human Rights Act, or any other form of legal redress that may be available to them, without reprisal or fear of reprisal in any form for doing so.
- f) The prevention of harassment and other discriminatory treatment at the College and in the broader community through a process of providing education and information is a necessary and important part of College policy.
- g) It is the College's belief that attempts should be made to resolve alleged cases of harassment and discrimination, where appropriate, before laying a formal complaint and that in resolving such allegations, principles of fairness shall apply.
9. THE COMPLAINT PROCESS:
- 9.1 The Complainant may approach any member of the College staff with whom they feel comfortable to discuss the complaint.
- 9.2 Every possible effort should be made to resolve an issue at the most effective level and as directly as possible. However, a Complainant may choose to register a formal complaint without resorting to any informal attempts at resolution.
- 9.3 The VP-CS will provide information regarding informal resolutions. Participation in the informal resolution process is completely

- voluntary and either party may withdraw at any time. If either party chooses to withdraw from the informal resolution process, the complainant may choose to pursue a formal complaint resolution.
- 9.4 The Quality and Privacy Officer and/or the Human Resources Department may be consulted to provide guidance in the implementation of this process.
- 9.5 The staff member may refer the Complainant to the appropriate external counseling resource for emotional support.
- 9.6 At any stage of the complaint process the Complainant or Respondent may have a support person present. The support person cannot have had any direct involvement in, or have been a witness to, the incident.
- 9.7 If efforts to resolve the situation to the satisfaction of the Complainant fail or are inappropriate for the given situation, the Complainant has the option of initiating a formal complaint by completing and submitting a QF003 (see a Formal Complaint Initiated, below).
- 9.8 A member of the College faculty, management (any individual who is in a staff supervisory role) or administrative staff, who becomes aware of any incidents of harassment or discrimination within the College community, where it is safe to do so, must intervene and attempt to remedy the situation. If unable to remedy, or if consultation is required, report the incident to the VPCS.
- 9.9 Vexatious Complaints - If a person, in good faith, discloses or files a Report that is not supported by evidence gathered during an investigation, the VP-CS may dismiss the complaint.

In the event that the VP-CS finds, following investigation, that a Report was frivolous, vexatious, an abuse of process, made in bad faith, or was made for the sole purpose of annoying, embarrassing, or harming the Respondent, the VP-CS may impose sanctions and/or discipline against the Complainant.

## 10. THE COLLEGE AS THE COMPLAINANT:

- 10.1 In certain cases, the College may decide to proceed with a complaint without the permission of the complainant(s) if:
- a) repeated complaints about the offending party(ies) have been received;
- b) an individual is at imminent risk of self-harm;
- c) an individual is at imminent risk of harming another;

- d) there are reasonable grounds to believe that others in the College or wider community may be at risk of harm;
- e) there is a requirement to report under the Occupational Health &amp; Safety Act; and/or
- f) the College is advised by legal counsel to do so.
4. 10.2 In these cases, the College becomes the complainant in pursuing formal resolution and the VP-CS will make the complaint on behalf of the College.

## 11. FORMAL COMPLAINT INITIATED:

- 11.1 Although the College encourages settlement of complaints at any stage of the process, when the spontaneous or informal response does not result in a satisfactory resolution to the issue, the complaint may be formally addressed by submitting a formal complaint. Any employee, student or other person engaged in College-related activities may register a formal complaint when an actual or perceived condition of harassment or discrimination is experienced.
- 11.2 A formal complaint of harassment or discrimination is initiated by completing Quality Form 003 and submitting it to the Office of the President.
- 11.3 Upon being notified of an incident involving harassment or discrimination, the President &amp; CEO or their designate, will take the appropriate action deemed necessary, including providing guidance regarding supports, the extent to which confidentiality may be maintained, and how Holland College will respond to the information received.
- 11.4 If it is determined that the complaint falls within the scope of this process, the complaint will be logged and assigned a serial number. A copy of the complaint will be forwarded to the VP-CS.
- 11.5 The President will: identify a member of College Management (AMCM) who would receive and review any procedural review that may   result from the complaint and notify them that a formal complaint has been received.
- 11.6 INTERIM MEASURES:

The rights and privileges of a Respondent may be restricted by the VP-CS before it makes a final determination about the alleged misconduct. Interim measures are not intended to be punitive but are intended to enable the provision of a safe environment for all members of the College community pending a substantive

determination as to the allegations. The VP-CS may impose interim measures immediately, without a hearing. Interim measures imposed may include, but are not limited to:

- a) Separation of academic and living arrangements between the Complainant, Survivor and/or Respondent (in the case of student involvement);
- b) Separation of workplace situations (in the case of College Staff Members), or of workplace and academic situations (in cases involving students and staff);
- c) Temporary suspension of the Respondent (in the case of a student) or temporary modification of the Respondent's academic program;
- d) Temporary suspension of the Respondent or amendment of duties of the Respondent (in the case of a College Staff Member);
- e) An order informing the Respondent that they are prohibited from attending at all or part of any campus of the College; and/or a no-contact order (i.e., an agreement, which is mutually undertaken by two or more parties, to refrain from contacting one another based on mutually specified conditions).

Such interim measures will be imposed only as necessary to protect any member of the College.  Any interim measure(s) shall ensure that procedural fairness, as applicable in the context, is maintained and shall be commensurate with the scope and severity of the alleged occurrences.

Interim measures do not represent a finding of guilt or misconduct.

Any interim measures put into place will be communicated in writing and will be regularly reviewed.

- 11.7 The VP-CS will strive to balance the complainant's wishes (including the decision to investigate the incident) with the College's need to take appropriate action to promote a safe working and learning environment.
- 11.8 The VP-CS will: designate a College Representative to speak with the alleged offender and provide them with a copy of the complaint form, ensuring that all personal contact information is redacted. The College Representative who has been asked to speak with the alleged offender will:

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- i. provide them with a copy of the complaint form, ensuring that all personal contact information is redacted, and any supporting documents, as well as an invitation to provide a written response to the allegations;
- ii. explain to them that they should refrain from any contact with the complainant;
- iii. if they are a student or a member of College staff, provide them with information on counseling services or other forms of assistance that may be available to them; and
- iv. provide them with a copy of this process and explain the process that will be followed.
5. 11.9 The AMCM for this complaint will not be provided with any information regarding the nature or the circumstances of the complaint until the matter has reached final resolution to the satisfaction of all parties, or until they receive the request for a procedural review.

## 12. INVESTIGATION:

- 12.1 The VP-CS will, upon receipt of the completed QF003, appoint an Investigator and arrange for an investigation into the alleged incident (the 'Investigation'). The Investigator shall be a person with the appropriate skills, training and/or experience. The Investigator may either be a College Staff Member or an individual external to the College, as determined by VP-CS in their sole discretion.
- 12.2 The VP-CS will acknowledge/update both the Complainant and the Respondent in writing about the commencement of the investigation.
- 12.3 When an investigator is assigned, the Investigator takes charge of the complaint for the College until they have completed their investigation and submitted their report. The Investigator must be given full authority to fully investigate the allegation(s) that have been made.
- 12.4 At any time during the course of an investigation where police are not actively involved, the Investigator may recommend to the VPCS that the matter be reported to the police.
- 12.5 The role of the College appointed Investigator is to provide a report to the VPCS so they can decide on the College's response to the allegations. Where other authorities (ex. police, OH&amp;S) are also conducting an investigation into the same incident, the Investigator shall cooperate with those investigations.

- 12.6 All Community Members are encouraged to meet with the Investigator if requested to do so and to participate in good faith.
- 12.7 The Investigator submits their report to the VP-CS who will render a decision on behalf of the College. When other external investigations into the incident are still on-going, the VP-CS will render a decision while reserving the right to revise the decision pending the outcome of the other investigations.
- 12.8 The VP-CS shall aim to hold in-person meetings when providing a decision to the Complainant and Respondent and endeavor to provide a written decision to both the Complainant and the Respondent. However, in cases of extenuating circumstances, the process may be adapted as necessary.

## 13. SANCTIONS:

- 13.1 When a complaint of harassment, or discriminatory treatment is proven, the VP-CS is responsible for making a decision regarding the appropriate sanction for the offence(s) and for ensuring that any disciplinary action is imposed against the offending party.
- 13.2 If it is proven that the allegations of harassment or discriminatory treatment are frivolous or vexatious, disciplinary action against the complainant will follow.
- 13.3 The disciplinary action shall be commensurate with the scope and severity of the occurrences. Potential sanctions may include but are not limited to reprimand, warning, probation, suspension, demotion, expulsion, termination or exclusion from the College's premises.
- 13.4 Cases which involve an immediate threat to the safety of either students or staff will be dealt with immediately through a formal discipline process.

## 14 PROCEDURAL REVIEW:

- 14.1 If the Complainant and/or the Respondent believe that due process has not been followed, or if they have new evidence that was not available at the time of the decision, they may request a Procedural Review
- 14.2 In the event that the Complainant or Respondent wish to request that the decision of the VP-CS be reviewed, a Procedural Review can be initiated by completing a Quality Form 014 Request for Procedural Review. A completed Request for Procedural Review form shall be submitted to the President's Office, Senior Executive Assistant for processing. This must be done by the Complainant

- and/or Respondent within fourteen (14) working days following the rendering of the decision.
- 14.3 The request must contain a copy of the VPCS's decision, the grounds for the Review, the outcome sought, a full statement supporting each ground for the Review, and all evidence relied upon by the appellant in support of their Procedural Review. The Procedural Review will not be accepted by the President's Office, Senior Executive Assistant, unless the information is complete.
- 14.4 Filing a Procedural Review will not stay, or delay, the implementation of any sanction(s) imposed, except where the AMCM otherwise so orders, upon written application of the Appellant. The AMCM may decide within seven (7) working days of receipt of the written application of the Appellant whether to stay the implementation of any sanction(s) imposed pending their written decision.
- 14.5 An appellant may only raise the following grounds for Procedural Review:
- New evidence not available at the time of the earlier decision has been discovered, which casts doubt on the correctness of the decision;
- There was a serious procedural error(s) in the Investigation and/or the rendering of a decision which was prejudicial to the appellant;
- 14.6 Upon receiving the Procedural Review request, the AMCM will, within seven days, determine whether the request should be allowed and shall provide a written decision, with reasons, to the relevant parties. The AMCM may seek confidential legal advice during the course of the Review and/or in rendering their decision.
- 14.7 Notwithstanding the Holland College Student Code of Conduct, Quality Process A09 (Student Misconduct), and Quality Process A10 (Student Appeals), neither the Complainant nor the Respondent has a right of appeal under Quality Process A10 (Student Appeals), or any other right of appeal outside of the Administrative Regulation, in matters of Harassment and Discrimination

## 15. EDUCATION AND TRAINING:

The VP-CS shall establish educational initiatives within the College in order to educate members of the College community regarding all aspects of harassment, and discrimination, including the significance and consequences, and shall require training sessions for instructional and management personnel where necessary.

## 16. CONTRACTORS:

All contractual relationships entered into by the College will be governed by a standard contract compliance clause stating that contractors must comply with this Policy and the PEI Human Rights Act, including co-operating in investigations. Breach of the clause may result in penalties, cancellation, or other sanctions.

## 17. RECORDS:

- 17.1 Initially and while any investigation or other process is underway, all records will be maintained by the VP-CS. The Office of the President is notified that a file has been opened so an official case serial number can be assigned.
- 17.2 When the case is closed the complete confidential file will be delivered to the Office of the President for storage. When the file remains open for longer than two (2) months, monthly status updates will be provided to the Office of the President.

## 18. RISK MANAGEMENT OF THE COMPLAINT:

- 18.1 A Quality Concern is a condition, situation, or circumstance that creates the opportunity for a problem to occur. Receiving a complaint raises the question that a 'Quality Concern' may exist. Generally, in the case of a complaint something has already happened, however a Quality Concern should still be considered.
- 18.2 Applying the Risk Management Protocol (RMP) to the complaint provides an opportunity to assess it from a risk perspective, implement corrective action, and identify any opportunity for improvement.
- 18.3 Risk management of a complaint does not change the process for handling of complaints. The process for handling complaints described in this document is essentially a risk management process. What is new is the focus on handling any concerns and risk that may be associated with the complaint.
- 18.4 At any time during or after the investigation of a complaint, if a Quality Concern or an opportunity for improvement is identified the RMP is applied. Starting a RMP process does not affect the complaint handling process. The goal of initiating a RMP at any time is to address the Quality Concern or opportunity that has been identified in an expeditious manner.

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<small>Source: [https://sam.hollandcollege.com/shared/QMS/Policy/30/AR-30-01-1.pdf](https://sam.hollandcollege.com/shared/QMS/Policy/30/AR-30-01-1.pdf)</small>
