A Closer Look at Connecticut
Connecticut requires employers with fifty or more employees to provide two hours of harassment training to all supervisory employees within six months of the assumption of a supervisory position.¹ Unlike California law and federal law, this is not an ongoing requirement. However, the regulations implementing the Connecticut law specifically state, "While not required by these regulations, the Connecticut Commission on Human Rights and Opportunities ("CHRO") encourages an employer having fifty (50) or more employees to provide an upgrade of legal interpretations and related developments concerning sexual harassment to supervisory personnel once every three (3) years."² The CHRO officially approved online training as a training solution in 2003.

With respect to Connecticut's law, ELT's programs not only include those items that the Regulations mandate³, but also content that encompasses the seven optional recommendations for harassment training:

1. Taking complaints seriously.
2. Providing exercises.
3. Teaching interpersonal skills.
4. Advising employees of strategies to avoid the negative effects of sexual harassment.
5. Advising as to the benefits of learning about the subject.
6. Presenting and explaining the employer's policy.
7. Discussing perceptual and communication differences.

The Connecticut law further specifies that the training is to be in "clear and understandable language."

Simply referring learners to the text of the Connecticut statute, or to a bulleted summary of the statute's requirements is insufficient for compliance. The substance of the required training content must be effectively integrated into a high-quality, interactive learning experience.

The Danger of Special "State Versions" of Training Programs
Recently, with the attention generated by California's new harassment training statute (AB 1825), some training providers have begun to market different "versions" of their courses for California and Connecticut. Learners in select states are exposed to special screens and features that include content designed to address state requirements. These programs have been quickly developed to capture a market opportunity.

Clearly this "add on" approach is needed if the programs originally created by these providers lack the critical content required by the state statutes and are insufficient in terms of length. The absence in the original programs, however, would suggest potential non compliance with federal law. For example, the Connecticut statute requires harassment training: "[d]iscussing strategies to prevent sexual harassment in the work place."⁴ While this is a clear requirement of training in Connecticut, it is certainly not unique to that state and is a basic component of any effective harassment prevention training program.

Establishing a Consistent, National Training Program
It is strongly recommended that one national version of a training program be used for all fifty states. Increasingly, organizations cross state and national boundaries. Managers stationed in New York may be transferred to California, while others may be relocated to other states. Individual managers in today's digital age can easily be supervising employees in many different states. It is too cumbersome to provide several different versions of the course and track compliance.

Sexual Harassment and other Prohibited Harassment are not concerns isolated within two States. The California and Connecticut requirements are not hyper-technical or "outside the mainstream." In New York, Texas, Florida and other states, it will be hard to explain why a more comprehensive course is used in California and Connecticut.  Moreover, it is only a matter of time before statutes and case law in other states endorse the "substantive" features emphasized in California and Connecticut.

Additionally it should be recognized that legal standards, definitions, and training requirements will continue to change over time. To the greatest extent possible, ELT anticipates these changes and incorporates "state of the art" comprehensive learning into its courses. It also monitors legal changes through its exclusive content provider, Littler Mendelson. When needed, automatic improvements are made to the courses to ensure compliance. This commitment to quality and ongoing review are ELT hallmarks and part of our commitment to be your partner, not merely a vendor.