On October 1, 2019, the clock begins to tick on Connecticut’s new training requirements under the “Time’s Up Act” (Public Act No. 19-16 together with Public Act No. 19-93). This law amends Connecticut’s existing workplace discrimination statutes to require employers with 3 or more employees to provide sexual harassment training to its employees by October 1, 2020. Employers with less than 3 employees must provide training to its supervisors. Prior to the new law, Connecticut only mandated sexual harassment training for employers with 50 or more employees. The new law also imposes stringent notice requirements on all employers.
The following describes some of the key aspects of the obligations imposed on Connecticut employers:
What Are The Training Requirements?
• Employers must provide 2 hours of sexual harassment training to all employees or supervisors as applicable
• Training must be supplemented at least every 10 years
• Employees who were provided sexual harassment training after October 1, 2018 are exempt from the new requirements
• New employees or supervisors, as applicable, must be trained within 6 months of employment
What Are The Notice Requirements?
• Employers with at least 3 employees must provide, within 3 months of the employee’s start date, information regarding the illegality of sexual harassment and remedies available to victims (note: providing a link to the Connecticut Commission on Human Rights and Opportunities (CHRO) website regarding sexual harassment is deemed sufficient)
• Information regarding the illegality of sexual harassment and remedies available to victims should also be posted, when published by the CHRO
Employer To-Do List:
• Schedule mandatory training for employees and supervisors, whether through a private human resources consultant, in-house human resources department, or through the CHRO
• Keep detailed records of training and attendance
• Review personnel policies and existing sexual harassment language and procedures to ensure compliance with the new law
• Evaluate onboarding processes to ensure compliance with the new law
For more information, please contact Daniel B. Fitzgerald (dfitzgerald@brodywilk.com) or another BW attorney.