Below is the Society for American Archaeology Meeting Safety Policy and Code of Conduct at SAA events. For questions about how this policy is implemented, including how to request SAA intervention for the safety of meeting participants, see also the Meeting Safety Policy FAQ.
This policy (“Policy”) defines a code of conduct for attendees of the SAA Annual Meeting and other SAA events and mandates response to incidents of misconduct in activities sponsored by the SAA. This Policy will be reviewed and updated, as
needed, every three years unless events and situations necessitate earlier action.
Everyone is entitled to a safe and harassment-free experience when participating in SAA activities. The SAA understands that participation at its events is an important part of career development and affirms the values of respect, equity, multicultural
pluralism, and nondiscrimination at these gatherings. Harassment harms the individual. Harassment also damages the SAA community by discouraging participation in SAA events and compromising the exchange of ideas that is at the center of the SAA’s
mission to promote and stimulate interest and research in the archaeology of the Americas and beyond.
Because of the importance of the meeting to career development and concerns at the Society about inclusion of marginalized groups in the Society’s events, the SAA has elected in this Policy to give priority to survivors of harassment and assault and to ensure their ability to participate freely in SAA events.
This policy applies to all meeting attendees at the SAA Annual Meeting and any SAA events, which includes the conference rooms and organized sessions of the SAA, workshops, excursions, receptions, webinars, and SAA committee, task force, and interest group meetings.1 Although reportable incidents are not limited to those occurring at the Annual Meeting and SAA events, any expulsions or restrictions are limited to areas under SAA control. For example, the SAA can bar or exclude an individual from conference sessions, exposition halls, SAA meetings, or social events; however, the SAA’s ability to restrict individuals from spaces accessible to the general public is limited.
Attendee Health and Safety
When any event participant discloses or reports an incident of misconduct, the SAA’s first immediate priority will be the health, safety, and well-being of the attendee. Except in emergency situations, where the venue policy and procedure take precedence, the SAA Executive Director and SAA President, in consultation with legal counsel and hotel/convention center security, will determine whether the involvement of local law enforcement is necessary or prudent.
II. CODE OF CONDUCT
SAA meeting participants involved in SAA activities and events are expected to conform to the principles and provisions of this policy and to the SAA Principles of Archaeological Ethics
The following behaviors are prohibited at the SAA Annual Meeting and SAA events:
- Harassment of any kind, including sexual harassment, sexual assault, and coercion
- Physical or verbal abuse, including bullying
- Unwelcome comments and/or exclusionary behaviors related to an individual’s age, sex, gender identity and expression, perceived sexual identity, appearance or body size, military status, ethnicity, individual lifestyle, marital status, sexual orientation, physical or cognitive abilities, political affiliation, race, religion, or nationality
- Intimidation, stalking, or following
Any attendee who is required by their employer or by a legal process to refrain from certain behaviors or from contact with certain individuals is expected to adhere to those restrictions while participating in all SAA activities. Violation of employer requirements and/or legal restrictions will constitute a violation of this Code of Conduct if disclosed or reported.
Prohibition against Retaliation
Retaliation is when someone penalizes another person for:
- Reporting, or expressing an intent to report, what the person believes in good faith to be assault, harassment, or any conduct prohibited by the SAA as stated herein
- Assisting another in reporting assault or harassment, or any conduct prohibited by the SAA
- Participating in any SAA inquiry, review, or investigation pertaining to misconduct
- Having previously reported assault, harassment, or misconduct, and/or having participated in an inquiry, review, or investigation, whether the potential violation occurred at SAA or elsewhere
SAA strictly prohibits retaliation to ensure that SAA event participants feel comfortable coming forward with their concerns without fear of reprisal. Any person who engages in retaliation in violation of this Policy will be subject to barring or expulsion from SAA events, possible termination of membership, or other disciplinary action.
III. OMBUDS AT THE SAA ANNUAL MEETING
For each SAA Annual Meeting, the SAA will designate ombuds (“Ombuds”) to serve as confidential resources for meeting attendees. The primary duties of the Ombuds are (1) to work with meeting attendees to explore and assist them in determining options to help resolve conflicts, problematic issues, or concerns, and (2) to bring systemic concerns to the attention of the organization for resolution. The Ombuds retained by SAA for its Annual Meeting shall follow the Standards of Practice and Code of Ethics of the International Ombudsman Association.
The Ombuds will operate in a manner to preserve the confidentiality of meeting attendees who come to them, will maintain a neutral/impartial position with respect to the concerns raised, and are independent of formal SAA organizational structures.
What an Ombuds Does2
Activities and functions most frequently undertaken by an Ombuds include, but are not limited to:
- Listens and understands issues while remaining neutral with respect to the facts. The Ombuds doesn’t listen to judge or to decide who is right or wrong. The Ombuds listens to understand the issue from the perspective of the individual. This is a critical step in developing options for resolution.
- Assists in reframing issues and developing and helping individuals evaluate options. This helps individuals identify the interests of various parties to the issues and helps focus efforts on potential options to meet those interests.
- Guides or coaches individuals to deal directly with other parties, including the use of formal resolution resources of the organization. An Ombuds often seeks to help individuals improve their skill and their confidence in giving voice to their concerns directly.
- Refers individuals to appropriate resolution resources. An Ombuds may refer individuals to one or more formal organizational resources that can potentially resolve the issue.
- Assists in surfacing issues to formal resolution channels. When an individual is unable or unwilling to surface a concern directly, the Ombuds can assist by helping give voice to the concern and/or creating an awareness of the issue among appropriate decision-makers in the organization.
- Facilitates informal resolution processes. An Ombuds may help to resolve issues between parties through various types of informal mediation in cases where parties consent to this informal process.
- Identifies new issues and opportunities for systemic change for the organization. The unique positioning of the Ombuds serves to provide unfiltered information that can produce insight to issues and resolutions. The Ombuds is a source of detection and early warning of new issues and a source of suggestions of systemic change to improve existing processes.
What an Ombuds Does Not Do
Because of the informal, neutral, confidential, and independent positioning of an Ombuds in an organization, they typically do not undertake the following roles or activities:
- Participate in formal investigations or play any role in a formal issue resolution process.
- Serve in any other organizational role that would compromise the neutrality of the Ombuds role.
- Receive notice for the organization.
- Make binding decisions or mandate policies.
- Create or maintain records or reports of individual visitors and individual consultations for the organization.
For the SAA Annual Meeting, the Ombuds will not be archaeologists. The SAA Ombuds will be as visible as possible at the Annual Meeting so as to be easily identified by meeting attendees.
SAA Ombuds may, with the permission of the individuals who come to them, make recommendations to the SAA President and Executive Director about specific actions that might enhance the safety and well-being of the individuals while at the Annual Meeting. In situations where the Code of Conduct is implicated, the SAA President and Executive Director shall advise the individual of the disclosure and reporting process outlined in Section IV below.
Ombuds will be on-site and accessible during the Annual Meeting and available by e-mail, phone, and for face-to-face meetings. Ombuds’ contact information will be published in all SAA Annual Meeting collateral materials (printed and online), including on SAA meeting badges.
Ombuds Selection and Identification
The SAA Ombuds retained for the SAA Annual Meeting shall hold the CO-OP® certification from the International Ombudsman Association, or possess the appropriate professional qualifications and experience to fulfill the obligations and duties as described herein. At the SAA Annual Meeting, there shall be at least one Ombuds. If there are more than one Ombuds, they shall be of different genders. The Ombuds positions will be filled by the SAA Executive Director after candidate interviews have taken place with a panel made up of the SAA President or designee(s) and SAA Counsel. Upon selection, the SAA Annual Meeting Ombuds’ names and contact information will be published in all appropriate Annual Meeting collateral materials. The SAA Ombuds will be as visible as possible at the Annual Meeting and be clearly badged as the “Ombuds.”
The Ombuds will summarize for the Board within two (2) months of the Annual Meeting basic demographics and problem categories of those who utilized the service (without any identifying information) at the SAA Annual Meeting and will provide any feedback and recommendations the SAA might wish to consider regarding future meetings.
IV. DISCLOSURE AND REPORTING AT THE SAA ANNUAL MEETING
SAA encourages reporting of any conduct in violation of the Code of Conduct in Section II above, regardless of the identity of the offender. While SAA encourages individuals to firmly and promptly notify the offender that the behavior is unwelcome, SAA also recognizes that power and status disparities between the offender and the recipient of the offensive conduct may make such a confrontation problematic. Consequently, such direct communication is not a requirement or prerequisite for filing a complaint.
Any meeting attendee may reach out to the SAA Meeting Ombuds. This is an independent, informal, and confidential process that enables attendees to discuss any matter of discomfort or distress. The topic of concern may have occurred at an SAA event or elsewhere, or at any point in the past. Connecting with the Ombuds does not require identifying the individual against whom the report is being made (“Subject Individual” 3) nor naming the Attendee to the Subject Individual(s) or to the SAA.
Ombuds visits are intended to explore creatively the range of legal, institutional, policy, and personal options and to discuss with the visitor benefits and disadvantages in order to help the individual identify solution(s) that best support them.
While high-level data about the overall categories and types of issues will be shared with the Board by the Ombuds (in the interest of improving the meeting in the future), the Ombuds will adhere to their obligation of confidentiality (unless the individual consents to disclosure), and no specific or identifying information will be shared with the SAA.
Visiting an Ombuds is not mutually exclusive with other processes (e.g., disclosure or report).
Disclosure and Report
Any SAA member or participant at the SAA Annual Meeting (“Attendee”) may submit a disclosure or a report (as defined below) to the SAA President or Executive Director. Reports and disclosures can be made orally or in writing. There may be circumstances, particularly with Reports, where an oral report may need some written documentation. The SAA President and Executive Director will be the primary point of contact for the Attendee. Attendees may report incidents with or without identifying the Subject Individual. For purposes of this Policy, the following definitions shall apply:
Disclosure (hereinafter “Disclosure” or “Disclosures”) occurs when an Attendee notifies the SAA of a violation of the Code of Conduct or other misconduct and requests assistance from the SAA to enable the Attendee’s
continued safe participation in SAA activities. The violation may have occurred at an SAA event or elsewhere, or at any point in the past. Disclosure does not require further investigation or identifying the Subject Individual(s). Disclosure does
not require naming the Attendee to the Subject Individual(s). A Disclosure may be made to the SAA President or Executive Director.
The Attendee’s identity shall remain anonymous, unless the Attendee elects to be identified.
In cases where a Disclosure is made without identification of the Subject Individual, actions that may be taken will be limited to making accommodations for the Attendee, such as arranging for escorts to, from, and during SAA events at the Annual Meeting.
Reporting (hereinafter “Report” or “Reports”) occurs when an Attendee notifies the SAA of a violation of the Code of Conduct, and requests that the SAA review the matter and take action against the Subject Individual to enable the Attendee’s continued safe participation in SAA activities. A Report may be made to the SAA President or Executive Director.
Reporting requires that an Attendee identify the Subject Individual. A Report will require a description of the alleged incident of misconduct from the Attendee and may be strengthened by statements from any witnesses to the incident.
The SAA President and Executive Director may provide the Subject Individual with a description of the incident and request a timely response. The SAA President and Executive Director will reiterate the non-retaliation provision of the Code of Conduct to the Subject Individual.
Disclosures and Reports under this Policy may be made orally or in writing. To assist Attendees, a form for submission of a written Disclosure or Report is attached to this Policy as Appendix A, and all Attendees are encouraged to use this form. The Attendee may designate a third party to represent them when submitting a Disclosure or Report, provided the third party can present written proof or confirmation of such designation to ensure such third party is authorized to speak on the Attendee’s behalf (e.g., signed letter/affidavit). Individuals who are submitting Reports on behalf of other SAA members or individuals should use the form and note that it is on another person’s behalf.
Role of the Ombuds
Attendees who submit a Disclosure or Report will be encouraged to speak with the SAA Ombuds at the Annual Meeting as well. The Ombuds will explore with the Attendee ways to stay safe and ways to participate as fully as possible in the meeting. If a formal report has not been submitted by the Attendee (in cases where a Disclosure has been made), the Ombuds may discuss the option of filing a Report with the SAA as outlined in this Policy; a complaint with the Subject Individuals’ employing institution or local law enforcement; or a grievance with the Register of Professional Archaeologists or another adjudicating body; along with exploring local, institutional, legal, and interpersonal options.
The Ombuds may, if appropriate, mediate or otherwise assist the Attendee and Subject Individual in reaching a resolution, particularly in cases of misunderstandings, if the parties agree to that process.
THE SAA PRESIDENT AND EXECUTIVE DIRECTOR, IN CONSULTATION WITH SAA LEGAL COUNSEL, SHALL BE EMPOWERED WITH THE DISCRETION TO TAKE ACTION AT THE SAA ANNUAL MEETING.
Actions may include, but are not restricted to, the following:
- Providing access to escorts to, from, and during events for the Attendee
- Removing the Subject Individual from the Annual Meeting
- Requiring the Subject Individual to modify and/or restrict his or her behavior and activity at the SAA Annual Meeting
- Other reasonable steps, consistent with the nature of the alleged misconduct
The SAA President and Executive Director will complete a written memo, summarizing the facts obtained and the resolution. The Attendee and Subject Individual will receive a copy. There may be circumstances in which identities shall be left out or redacted from the memo.
The SAA President and Executive Director shall be responsible for prompt updating to the Attendee about the actions taken. The SAA President and Executive Director will be responsible for notifying the Subject Individual about actions the SAA is taking.
The SAA President and Executive Director’s memo shall be sent to the Findings Verification Committee referenced in Section V below for further review and determination of whether or not the Subject Individual should be barred from future SAA Annual Meetings or events.
V. DISCLOSURE AND REPORTING PRIOR TO THE SAA ANNUAL MEETING
Any SAA member or participant at the SAA Annual Meeting (“Attendee”) may submit a Disclosure or Report up to 30 days prior to the opening session at the SAA Annual Meeting by e-mailing the SAA President (email@example.com) and/or Executive Director (firstname.lastname@example.org). Attendees may use a third party to represent them when submitting a Disclosure or Report to SAA and for purposes of discussing next steps with the SAA, provided the third party presents written proof or confirmation of such designation to ensure such third party is authorized to speak on the Attendee’s behalf (e.g., signed letter/affidavit).
Article IX: Meetings and Voting, Section 4 of the SAA Bylaws states:
Upon being presented with credible evidence that an individual has been found, by a court of competent jurisdiction or an administrative or regulatory body, to have engaged in conduct or actions contrary to the ideals, objectives, and accepted standards of the Society as set forth in these Bylaws, Board policies, or the SAA Principles of Archaeological Ethics, the Board may bar that individual from attending the Annual Meeting and other SAA-sponsored events.
Such conduct or action shall include, but is not limited to, sexual assault and harassment.
For the purposes of this policy, the Register of Professional Archaeologists’s Grievance Process is considered an administrative body.
Registrants for the SAA Annual Meeting are required to self-certify as follows:
I am not and have not ever been the subject of adverse findings from a discrimination or harassment lawsuit or administrative complaint; and
I have not been found at fault in a disciplinary action, such as suspension or termination of registration resulting from a Register of Professional Archaeologists’ grievance investigation.
A list of the names of advance registrants will be posted online behind the log-in wall for other advance registrants and members to review within two days of advance registration closing. Advance registrants who are on the program are also included in the Preliminary Program when it is published online.
Disclosures submitted under advance reporting shall be reviewed by the SAA Executive Director, the SAA President, and SAA Counsel for purposes of arranging any accommodations requested to ensure the Attendees’ safe participation
at the SAA Annual Meeting. The SAA Ombuds for such Annual Meeting will be made aware of the matter and briefed on the accommodations made.
Reports submitted up to 30 days prior to the opening session at the Annual Meeting shall be reviewed by the Findings Verification Committee (“Committee”).
Findings Verification Committee
The Committee shall be made up of no fewer than three (3) SAA members, appointed by the Board of Directors to serve staggered three (3)-year terms. Beginning in 2021, at least one of the committee members will be elected by members for a three (3)-year
term. The Committee shall be authorized to review Reports and shall be charged with recommending to the Board under Article IX, Section 4 of the SAA Bylaws whether SAA members should be barred from future SAA events.
The Committee is charged by the Board of Directors with verifying credibility of evidence and recommending to the Board whether an individual should be barred from attending the SAA Annual Meeting or other SAA-sponsored events and for what period of time. In determining its recommendation, the Committee shall receive and review evidence that the Subject Individual has been found, by a court of competent jurisdiction or an administrative or regulatory body, to have engaged in conduct or actions contrary to the ideals, objectives, and accepted standards of the Society as set forth in these Bylaws, Board policies, or the SAA Principles of Archaeological Ethics. The Committee shall not have the authority to independently receive Reports, or to initiate its own inquiry, review, or investigation with respect to any individual or group.
The Committee’s deliberations shall include SAA Counsel, identified to it by the SAA President or Board of Directors.
Committee Report and Recommendation
Upon determining that the documentation underlying the Report is sufficient and credible, the Committee shall document its findings and recommend to the Board whether the Subject Individual should be barred from the SAA Annual Meeting and other SAA-sponsored
events. The Committee recommendations shall be made available to the Attendee (or Attendee’s representative in such cases), the Subject Individual, and the Board of Directors.
If an adverse finding against the Subject Individual is recommended by the Committee, the Subject Individual may submit objections to the Board of Directors within ten (10) business days of receipt by the Subject Individual, and provide arguments as to why the Committee’s recommendations should not be adopted.
If the Committee’s determination is adopted by the Board of Directors, SAA Staff shall be directed to implement all appropriate administrative steps to ensure the Subject Individual is barred from registering for or attending the relevant future SAA events, including the Annual Meeting. Such steps may include measures to identify and prevent the Subject Individual from on-site registration for the relevant SAA events, and may involve asking registrants to provide identification when they pick up their badges.
VI. INVESTIGATION REQUESTS
In some cases, SAA members have found that they are unable to produce a finding to begin or to complete the advance reporting process. The following process (“investigation request”) provides a process through which the Society for American Archaeology (SAA) will work with the Register of Professional Archaeologists (Register), a regulatory body for purposes of this policy, to handle referrals concerning potential misconduct.
Once a report has been filed with the SAA President or Executive Director, and/or the Findings Verification Committee Chair, the Findings Verification Committee (FVC) will evaluate any Report using above procedures. In cases where the Report includes a Finding, the FVC may be able to complete their recommendation to the SAA Board without making a request for investigation (Referral) to the Register. However, many times Reports do not include a finding, either because no Finding has been made or because the Finding is sealed or otherwise unavailable.
In cases in which the Report lacks a Finding and in which the person filing the complaint (Threatened Individual/ Third Party Advocate) and the subject of the Report (Subject Individual) are SAA members, the FVC may make a Referral to the Register. The FVC chair will work with the SAA Meetings and Membership Manager to ensure that the Subject Individual is a SAA member or a registered SAA event attendee and that the Threatened Individual is a SAA member or a registered SAA event attendee. The person making the complaint does not have to be the Threatened Individual but can be a Third-Party Advocate. In cases where the Threatened Individual has filed an onsite Report, the SAA Meeting Safety Policy will proceed.
In the event that the FVC is unable to make a determination on the information presented in a Report based on the absence of appropriate findings, the FVC chair will offer the Report submitter the option to move to a next phase of review through the Register’s Grievance Process or not, understanding that without the added review the FVC has concluded that it would not otherwise be able to recommend SAA action against the Subject Individual for lack of findings relevant to the claim.
Once a Referral has been made by the Chair of the FVC, the Report will be forwarded to the RPA Grievance Coordinator for review under the Register’s Grievance Process using the Register’s Code of Conduct. By forwarding the Report, the SAA agrees to the terms of the Register’s Grievance Process. The reporting party will be notified of this referral by the SAA at the time that this has been done. If a Grievance Committee is convened, that Committee shall follow the Register’s Grievance Process and RPA notification procedures would prevail from this point forward. For non-RPA registrants, the highest level of action by the Register shall be a Grievance Coordinator Report to the SAA FVC. For RPA registrants, the Register may also take action independent of SAA.
The Referral will be evaluated by the Register using its Code of Conduct. This process follows Register’s procedures, available here [https://rpanet.org/about-grievance]. The decision to review or decline the Referral will be conveyed to the FVC chair consistent with the Register’s procedures for making a determination of merit. Updates provided to the FVC chair will also follow the Register’s procedures.
The Register’s Grievance Coordinator will report their finding to the FVC. By accepting receipt of the findings, SAA agrees that any materials will not be shared beyond the those specified in the SAA Meeting Safety Policy FAQ. The findings report will include:
o Merit determination by the Grievance Coordinator
o A report on the nature, scope, and gravity of any finding
Per the SAA Meeting Safety Policy, the FVC evaluates all findings and then makes a recommendation to the SAA Board of Directors regarding any action in response to the finding. This does not preclude the Register from taking action separately in instances where the Subject Individual is also a Registrant. Any recommendation for action by the SAA shall be made without regard to the RPA registration status of anyone under investigation.
VII. CONFIDENTIALITY, RECORDS, AND REPORTING
All matters falling under this Policy will be held strictly confidential within the SAA Board of Directors, Findings Verification Committee, Ombuds, SAA Staff, and SAA Counsel. Confidentiality shall be maintained in the interest of protecting the identity
of any individual submitting a Disclosure or Report, any other individual party submitting the same, and/or the individual against whom a Disclosure or Report is being made, as well as to minimize legal exposure to the SAA subsequent to any inquiry,
review, or investigations conducted by the SAA or the Ombuds (“Inquiry” or “Inquiries”).
Notwithstanding the confidentiality of any Disclosure, Report, or Inquiry, the identity of any individual or party to a Disclosure, Report, or Inquiry may be made known on a need-to-know basis, with such individuals’ prior written consent, if such individuals so choose. The identity of Subject Individuals, as part of the reporting to the Board and SAA membership, shall be made consistent with the “Reporting” provisions of this Section V below. It is understood that when an adverse determination is made against a Subject Individual, the identity of such Subject Individual will be disclosed on a need-to-know basis, to effectuate the intent of this Policy.
All SAA deliberations with regard to any Disclosure, Report, or Inquiry, including but not limited to deliberations of the Ombuds, Findings Verification Committee, and SAA Board, shall be kept strictly confidential.
VIII. EDUCATION AND COMMUNICATION
The SAA will provide members with information about appropriate conduct and prevention of misconduct during the SAA Annual Meeting and other SAA events, including the presence of this Policy and contact information for the SAA Annual Meeting Ombuds.
Anti-harassment and all related policies will be posted on the SAA website.
SAA Annual Meeting communications, including web pages, e-mail, and any published materials, including the call for submissions and registration information, will include this Policy or hyperlinks to this Policy. The Policy will be printed in the final program, and a link to the Policy will be provided in the meeting mobile application.
The SAA will promote activities that reduce misconduct in the practice of archaeology, such as trainings for bystander interventions and workshops on reducing abuse, micro-aggressions, and implicit bias. The SAA will make available all information, including the process for making Reports, Disclosures, or filing complaints through social media outlets, where appropriate.
IX. EDUCATION AND COMMUNICATION
Claim—Any formal request by an SAA member seeking action under the SAA Meeting Safety Policy.
Claimant—Any person who submits a claim under the SAA Meeting Safety Policy.
Disclosure—A claim requesting personal support for safe participation at an SAA event. Disclosures do not require outside documentation and do not lead to action against a Subject Individual.
Event (of concern)—Any SAA-sponsored event for which a claimant seeks accommodation under the SAA Meeting Safety Policy.
Finding—Any determination by a court of competent jurisdiction or an administrative or regulatory body. This includes the RPA Grievance Process.
Referral – A formal request by the SAA (FVC chair) to the Register for Professional Archaeologists’ Grievance Coordinator to conduct a review according to the Register’s Grievance Process. Once a grievance has been referred, the case will proceed according to the Register’s grievance process.
Report—A formal request to prevent a Subject Individual from attending one or more SAA events in the interest of the safety of a threatened individual. Reports differ from Disclosures based on the provision of documentation demonstrating a verifiable finding against a Subject Individual.
RPA Greivance Process—A process defined and controlled by the Register of Professional Archaeologists (RPA) to enforce the RPA’s Code of Conduct.
Subject Individual—A person who has been accused of harassment and/or assault and from whom one or more threatened individuals seek protection during SAA events.
Third-Party Advocate—A person submitting a claim on behalf of a threatened individual, with their permission. This individual does not need to be an SAA member and/or a registered SAA event attender.
Threatened Individual—A person who has experienced harassment or assault from a Subject Individual and who seeks support to participate in one or more SAA events. This individual must be an SAA member and/or a registered SAA event attendee.
 SAA committee, task force, and interest group meetings take place in various venues; the Policy will apply, regardless of venue, for all committee, task force, and interest group meetings that are formally convened. The Policy will not apply to SAA events that are open to the public.
 Excerpted from the International Ombudsman Association.
 For the purposes of this Policy, “Subject Individual” refers to anyone against whom a report is being made, regardless of SAA membership status.