there are precidents about it - but they are a case to case thing
i think it went a bit like that - skype is NOT a medium which counts towards a sanction - unless what is said there is directly and/or a continuation of the forum. - so if a skype rant is directly related to the disco community and forum - it can - under circumstances be used for a sanction. ( i do believe that is what cannon once said ( over 2 years ago ) - but thats not a direct quote, just an interpretation of what he commented a long time ago. key points are "continuation of a forum rant/insult" and it was not to be used "on its own" )
but there has never been a 100% clear rule about it. - in the past there had been admins and mods trolling/abusing/insulting other members of the community in skype, too - as well as there are countless members who insult or scheme against other members of the community in skype or other media.
skye cannot be patrolled - skype can also be edited easily. it is also very easy to put conversations well out of context - so it may probably just support a violation that has already occured.
so it is circumstancial/situational i guess - entirely depending on who makes the judgement.