Author: Carol M. Goodman
As explained in our previous employment alert, all New York employers must conduct annual sexual harassment training and have a compliant sexual harassment prevention policy effective October 9, 2018. With that deadline looming, yesterday Governor Cuomo issued the final model sexual harassment policy (including the final model complaint form), the final model sexual harassment training program (along with an accompanying script), and the final FAQs containing the State’s guidance and interpretation of New York’s sexual harassment prevention policy and training requirements.
Of particular note for employers is the FAQ’s guidance on the timing of sexual harassment training. The FAQs explain that all employees must receive a compliant training by October 9, 2019, and then on an annual basis (using a date of the employer’s choosing) thereafter. This will allow all New York employers time to digest the final training issued by the State, and will allow New York City employers to coordinate their State-mandated training with the City’s own training requirement, effective April 1, 2019.
In light of the State’s final guidance and the upcoming October 9, 2018 deadline, employers should evaluate their current anti-harassment policies and trainings and contact their employment counsel if they have any questions.
