In 2019, the Connecticut General Assembly passed (and Governor Ned Lamont signed) Public Acts 19-16 and 19-93, together known as the Time’s Up Act (the “Act”). The Act requires Connecticut employers with at least one Connecticut employee and three or more employees nationwide to provide 2 hours of sexual harassment training to all Connecticut based employees. Employers with fewer than three employees nationwide need only provide “supervisory employees” based in Connecticut with two hours of training. Due to the ongoing COVID-19 pandemic, the Connecticut Commission on Human Rights and Opportunities (“CHRO”) extended the Act’s initial October 1, 2020 training requirement deadline to January 1, 2021.

Compliance Snapshot

  • All current employees must be trained by January 1, 2021.
  • New employees hired after October 1, 2019, must still be trained within six months of hire, despite the January 1, 2021 extension.
  • Employers are required to provide all new employees a copy of information regarding the illegality of sexual harassment and remedies available to victims.

Who must Provide and Receive Sexual Harassment Prevention Training under the Time’s Up Act?

Any employer with three or more employees nationwide must provide training to all Connecticut based employees. If an employer has fewer than three employees nationwide, only supervisory employees based in Connecticut must receive two hours of training. For example, if a New York-based company has ten employees in New York and one in Connecticut, that one employee in Connecticut would be subject to the training requirements.

What is the Deadline for Providing Sexual Harassment Prevention Training to Existing Employees?

The amount and timing of the training will depend on the employer’s size, as follows:

  • Employers with three or more employees nationwide – two hours of sexual harassment training must be provided to all employees. For existing employees, this training must be provided by January 1, 2021. All employees hired on or after October 1, 2019 must receive the training within six months of hire. For example, an employee hired on May 1, 2020, would need to be trained by November 1, 2020.
  • Employers with less than three employees – must provide sexual harassment training to supervisory employees only. This training must be provided by January 1, 2021, or within six months of an employee assuming a supervisory role.

Does the CHRO Provide a Model Training Program to meet the Act’s Requirements? 

Yes. The CHRO is required to develop and make available at no cost to employers an online training and education video or other interactive method of training and education to fulfill the requirements of the statute. After finishing the CHRO training, the employee will receive a certificate of completion in an email within 24 hours. Certificates from the CHRO are not required to prove an employee has completed the training. If an employer wants to keep track of compliance using their own methods, the employer may do so. An employer is not required to use CHROs training module and is able to use a training of its own choosing, as long as it contains the necessary elements.

What are the Notice and Posting Requirements?

Posting Requirement

Employers with three or more employees must post in a “prominent and accessible location” information concerning the illegality of sexual harassment and the remedies available to victims of sexual harassment.

Notice Requirement

Employers must provide a copy of the information about the illegality of sexual harassment and remedies available to victims of sexual harassment to each employee within three months after their start date. The information may be provided by e-mail only if the employer has provided the employee with an e-mail address or the employee has provided the employer with an e-mail address. Otherwise, an employer may provide it electronically by posting this information on the employer’s internet website. An employer may also comply with this requirement by providing an employee the link to the CHRO web page that describes the illegality of sexual harassment and the remedies available to victims of sexual harassment.

Sequoia Clients Only: Sequoia assists clients to meet their training requirements by partnering with ThinkHR to bring you access to various state-wide harassment prevention training programs and resources. Please reach out to your dedicated Sequoia representative for more information.

Additional Resources

If you have questions regarding the training requirements or the training provided by CHRO, employers may call 860-541-3400 or email [email protected] for assistance.

Disclaimer: This content is intended for informational purposes only and should not be construed as legal, medical or tax advice. It provides general information and is not intended to encompass all compliance and legal obligations that may be applicable. This information and any questions as to your specific circumstances should be reviewed with your respective legal counsel and/or tax advisor as we do not provide legal or tax advice. Please note that this information may be subject to change based on legislative changes. © 2020 Sequoia Benefits & Insurance Services, LLC. All Rights Reserved

Lizet Ramirez – Lizet is a Client Compliance Manager for Sequoia One, where she works with our clients to optimize and streamline benefits compliance. In her free time, Lizet enjoys live music, travel, hiking and spa days.