The national anti-sexual violence organization RAINN is performing an audit and assessing St. Paul’s School’s sexual misconduct prevention and response programming, according to the most recent semi-annual report by the New Hampshire Attorney General’s Office.
The report, authored by Independent Compliance Overseer Donald Sullivan, was released Tuesday, and gives updates about the audit, the school’s online reporting software, and the support available for students. The report is Sullivan’s second since taking the position in January 2021, and the fifth since the position was created in 2018. Sullivan stated that he found zero non-compliance in the last five months.
“I began at the School during the COVID-19 pandemic,” Sullivan wrote. “It is difficult to learn the ins and outs of an extremely busy institution steeped in tradition, and the restrictions required by the pandemic only hindered this process. A more ‘normal’ opening of school in the fall of 2021 has better allowed me to experience the culture of St. Paul’s School.”
Sullivan wrote that the 16-month audit by RAINN – officially known as the Rape, Abuse and Incest National Network – began in July 2021 and has examined the school’s policies, recruiting and onboarding, training and response. He said RAINN is almost done with the “discovery phase” and is beginning the “analysis phase.” RAINN staff are also administering surveys and conducting interviews to hear about people’s experiences with the school’s reporting and response system.
“This project exceeds the agreement with the Attorney General’s Office and will undoubtedly have a positive impact on the policies and procedures surrounding sexual misconduct at SPS, which will, in turn, increase confidence in the system,” Sullivan wrote. “The final result should be increased prevention, increased willingness to report, improved response and, ultimately, a positive shift in culture.”
Sullivan also wrote that the school no longer has a victim advocate from the Crisis Center of Central NH, since the previous advocate – who briefly offered support sessions to students in a former radio space in the Friedman Community Center – left the position to pursue further education at the end of the 2020-2021 school year. Sullivan wrote that the school is working to find a new advocate to fill the position.
Currently, the primary source of victim support is St. Paul’s Clark House Health Center, which has five counselors and one psychiatrist who comes to campus twice a month. Phone resources including RAINN, the Crisis Center of Central NH and Concord Police 24-hour hotlines are also advertised to students.
The school is continuing to use Maxient software to collect reports about incidents of misconduct. Sullivan’s document includes a list of 22 safety incident reports that the school received since September 2021, which include reports of current and historic sexual assault, as well as other incidents like drug possession. Since September 2021 there have been two current reports of sexual assault, both occurring off-campus, and three reports of historic sexual assault, including one on-campus and two off.
The overseer position was created at St. Paul’s School at the end of 2018, following a 14-month-long criminal investigation into the school’s handling of sexual assault reports. Rather than pursue charges of child endangerment, a misdemeanor-level offense, the school reached an agreement with state prosecutors to embed an overseer on the St. Paul’s School campus, who is tasked with reporting at least bi-annually to the Attorney General’s Office regarding St. Paul’s School’s compliance with all of the terms of the agreement.