The following are definitions of Sexual Abuse, Non-Consensual Acts, Sexual Misconduct, and Sexual Harassment, per Department of Justice (DOJ) Survey of Sexual Violence (SSV):

 

• Abusive Sexual Contact (Client-on-Client) - Contact of any person without their consent or of a person unable to consent or refuse. Contact between the penis and vagina or penis and anus including penetration, however slight; or contact between mouth and penis, vagina, or anus; or penetration of the anus or genital opening of another person by a hand, finger, or other object.

• Non consensual Sexual Acts (Client-on-Client) - Contact of any person without their consent or of a person unable to consent or refuse. Intentional touching, either directly or through clothing, of the genitalia, anus, groin, breast, inner thigh, or buttocks of any person.

• Sexual Harassment (Client-on-Client) - Repeated and unwelcome sexual advances, requests for sexual favors, or verbal comments, gestures, or actions of a derogatory or offensive sexual nature by one inmate directed toward another.

• Staff Sexual Misconduct (Staff-on-Client) - Any behavior or act of a sexual nature directed toward an inmate by an employee, volunteer, official visitor, or agency representative. Romantic relationships between staff and inmates are included. Consensual or non consensual sexual acts include: intentional touching of the genitalia, anus, groin, breast, inner thigh, or buttocks with the intent to abuse, arouse, or gratify sexual desire; or completed, attempted, threatened, or requested sexual acts; or occurrences of indecent exposure, invasion of privacy, or staff voyeurism for sexual gratification.

• Staff Sexual Harassment (Staff-on-Client) - Repeated verbal statements, comments, or gestures of a sexual nature to a client by an employee, volunteer, contractor, official visitor, or agency representative, including: demeaning references to gender or derogatory comments about body or clothing; or profane or obscene language or gestures

 

ICCS hired its first PREA Coordinator in 2015 with an eye towards complete compliance with the standards and better education and training for both staff and clients. When comparing the number of allegations in 2019 (19) to 2018 (21), you can notice a slight decrease in allegations which could be due to an increased practice of preventive measures by staff regarding some changes in our training.  

2019 represents the first year of the third PREA audit cycle. ICCS was successful in getting the Pueblo facility audited.  Looking forward, it is anticipated that an audit one time each year will satisfy the requirements of future audit cycles.

 

Upon reviewing the allegations for the 2019, most of the allegations occurred in areas where cameras cannot be placed (bathrooms, shower rooms, and living quarters). Some substantiated incidents occurred where cameras caught the behavior. The incidents don’t appear to warrant any fundamental shift in policy.

Looking at all facilities combined, the most prevalent need appears to just be continued training provided to staff members, especially given higher levels of staff turnover. Our PREA Coordinator has created a personalized training that is more specific to ICCS and each facility’s dynamics and layouts. ICCS has also started to bring in Rape Crisis Centers to facilitate PREA training. This was completed at ICCS Kendall and Weld.