PUBLIC NOTICE
Housing Authority of the Town of West Hartford

WHHA Policy Regarding Potential Abuse By External Participants

The West Hartford Housing Authority (“WHHA”) strives to provide services in an atmosphere of respect, collaboration, safety, and equality. WHHA is firmly committed to a workplace free from threatening, intimidating, abusive and/or harassing conduct from colleagues, program applicants, program participants or any others interacting with WHHA staff, and all employees have the right to be treated with dignity and respect.  WHHA has adopted an employment policy that addresses potential violence or harassment in the workplace; this policy is intended to address any potential for such conduct by external individuals engaging with WHHA staff, including applicants, tenants, and participants in any WHHA programs (hereinafter referred to as “External Participants”).

Threatening, intimidating, abusive and/or harassing conduct includes acts or omissions that would cause a reasonable person, based on the severity, nature, and frequency of the conduct, to believe that an employee was subject to abusive or violent behavior by an External Participant, including verbal as well as threatened or actual physical abuse (together, referred to as “Abuse”), creating an abusive work environment, which can include but is not limited to:

• Repeated verbal abuse from an External Participant in the workplace or related to an employee’s work duties, including derogatory remarks, insults, and epithets.
• Verbal, nonverbal, or physical conduct of a threatening, intimidating, or humiliating nature from or by an External Participant in connection with work duties in the workplace; or
• The sabotage or undermining of an employee’s work performance in the workplace by an External Participant.

Abusive and/or harassing conduct by any External Participant will not be tolerated.  WHHA will promptly and thoroughly investigate any reports of such occurrences or threatening, intimidating, abusive and/or harassing conduct. If an employee has suffered Abuse by an External Participant, the employee shall report that incident to his or her supervisor and the Director of the program. The Director shall review the reported Abuse and make a recommendation to the WHHA Executive Director regarding any proposed action in response to the reported Abuse.

With respect to the Housing Choice Voucher and Rental Assistance program administration, WHHA will enforce this policy by considering denying or terminating any State of Federal housing assistance, as supported through the following federal and State program provisions:

HCV Federal Regulation 24 CFR 982.552 – PHA denial or termination of assistance for family.

(c) Authority to deny admission or terminate assistance –

(1) Grounds for denial or termination of assistance. The PHA may at any time deny program assistance for an applicant, or terminate program assistance for a participant, for any of the following grounds:

(ix) If the family has engaged in or threatened abusive or violent behavior toward PHA personnel.

RAP State of CT Administrative Plan (Ch 15, pg. 2 -3 item #7)

Grounds for Denial or Termination of Assistance:

The HA will deny program assistance for an applicant, or terminate program assistance for a participant, for any of the following reasons:

#7. The family has engaged in or threatened abusive or violent behavior toward HA personnel.

• “Abusive” or violent behavior towards HA personnel” includes verbal as well as physical abuse or violence.
• Use of expletives that are generally considered insulting, racial epithets, or other language, written or oral, that is customarily used to insult or intimidate, may be cause for termination or denial.
• “Threatening” refers to oral or written threats or physical gestures that communicate an intent to abuse or to commit violence. Actual physical abuse or violence will always be cause for termination.

WHHA shall follow all regulatory, statutory and related rules in the process for terminating any housing assistance, including a hearing in the event that the External Participant requests a hearing.  WHHA shall also proceed to address and terminate any Abuse by an External Participant and take whatever legal or other actions appropriate for the circumstances for any violations of this policy and protect WHHA employees and property.