NYS issued its final guidance on the new sexual harassment policy and training requirements in effect for all New York employers. The state clarified that October 9, 2018 remains the deadline by which all employers must adopt a written sexual harassment policy and an anti-harassment training program. The state has issued model language and training documents for employers that need assistance developing those documents.
The final guidance clarified the date by which employers must conduct an annual training. There was confusion previously about the deadline, but NYS now states that all employees must complete anti-harassment training by October 9, 2019. After that date, the training must continue to be completed on an annual basis for all employees. The final guidance also states that new employees need to be trained as soon as possible after their start date; previously issued draft guidance had a stricter deadline of 30 days after a new employee’s start date.
The training requirement applies to all employees, including seasonal and temporary workers. It also applies to employees who may work in NYS only part of the time (only one day is enough), even if they’re based in another state.
If you have any questions or would like assistance with providing the requisite training to employees, please contact us.