A client recently wanted to know, "What's the best way to keep track of sexual harassment prevention training so that we are sure we stay compliant?"

It's a good question, especially since there is a somewhat unexpected twist to the requirements!

California state regulations permit employers to use individual tracking or training year tracking, or a combination of both, when keeping track of harassment prevention training.

Tracking Methods for Mandatory Harassment Prevention Training

Individual Tracking:
This lets you track the training that each person receives. You can track your training requirement for each supervisor on an individual calendaring basis. You measure two years from the date that the supervisor last completed training.

• For example: You promote a new supervisor on April 15, 2016. The supervisor receives harassment prevention training on September 22, 2016 - meeting the training requirement of within six months of hire or promotion. That supervisor must be retrained by September 21, 2018, to satisfy the every two years requirement.

Training Year Tracking:
You can designate a "training year" in which you train your supervisors. You must retrain all supervisors every two years by the end of the designated training year, even those newly hired or promoted supervisors that received training in the prior year.

• For example: You trained all supervisors in 2015 and schedule 2017 as the next training year. An employee was promoted to supervisor on February 5, 2016, and receives the initial training on June 10, 2016 - so, within six months of their promotion, as required. However, that supervisor must be retrained by December 31, 2017, to align with the company's training year schedule, even though it will be less than two years since the last training.

Training From a Previous Employer Counts

Note that you may not need to retrain newly hired supervisors who received sexual harassment training from their previous employers within the prior two years. The regulations allow employers to accept an employee's previous training as valid and to put that supervisor on a two year tracking schedule based on his/her prior training date.

However, the new employer must prove that the prior training was sufficient and meets the legal requirements of mandatory training law. In addition, the supervisor must read and acknowledge receiving the current employer's anti-harassment policy within six months of being hired or promoted.

We are here to help! If you have concerns about your mandatory sexual harassment prevention training, please Contact Us!

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