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Building & Facilitating a Comprehensive Clery Compliance Program

Building & Facilitating a Comprehensive Clery Compliance Program






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    Building & Facilitating a Comprehensive Clery Compliance Program Building & Facilitating a Comprehensive Clery Compliance Program Presentation Transcript

    • Building and Facilitating a Comprehensive Clery Act Compliance Program Stephen Shelow Gabriel Gates Steven Healy
    • Follow us onTwitter @margolishealy www.slideshare.net/margolishealy
    • Introduction  Who we are  The University & System  Division of Police & Public Safety
    • IfYou have a Problem…  …you have a Clery problem  High profile incidents  Congressional intent  Student activism
    • The Price of Non-Compliance  It’s not just about fines An ED review will significantly affect your institution  In 2011 alone, ED issued 2x the number of FPRDs issued the previous two years and five times the number of reports issued between 2006 - 2008
    • WhereWeWere Prior to 2011, our compliance approach was… 2011, everything changed Major Crisis Dept. of ED at our door step We needed assistance  Retained Margolis Healy
    • WhereWeWere Initial recommendations included creating a Clery Compliance coordinator Selling concept to University Developed job description; conducted national search GabeGates selected
    • WhereWe Are Focused program & approach Consistency – system wide High level support for approach
    • A Holistic Approach to Compliance Identifying our Campus Security Authorities (CSAs) across a 23 campus system by job function. (HRTraining/Definition Interpretation) Notifying all CSAs of their designation and responsibilities Revising procedures for collecting crime data  CSAs, Campus Law Enforcement, Local Law Enforcement, Student Conduct, etc.)
    • Developing Relationships  Margolis Healy & Associates (MHA)  Ongoing partnership with MHA  Clery Center for Security on Campus (CCSOC)  Partnership with CCSOC to develop a ground breaking “train the trainer” course  Liaising with Congressional delegation
    • Educating the Campus Community ATwo-Staged Curriculum: 1. Each Campus Security Authority receives initial classroom training  Clery Act requirements and University reporting procedures.  To date, roughly 200 trainings conducted. 2. All Campus Security Authorities are required to complete an annual online refresher training beginning in 2013. 3. Identified approximately 3,000 employees to receive training.
    • Increasing Awareness  Conduct “information sessions” to engage campus community onClery Act requirements, practices, and future endeavors.  Variety of audiences, including executive and academic leadership from University Park as well as campuses, Faculty Senate governance, and Intercollegiate Athletics.  University has devoted a renewed effort to encourage the reporting of crimes. “It is not only what we do, but also what we do not do, for which we are accountable.” Moliere
    • Standardizing Procedures  Forms, templates, and detailed guidance to everyone involved with reporting crime statistics:  Standardized Campus Security Authority Incident Report form  Comprehensive crime data reporting procedure for individual campus police/security agencies to report statistics  Standard request for information to all local law enforcement agencies  Clery Mapping for each of our campuses  TimelyWarning Decision Matrix  Testing emergency response and evacuation procedures
    • EnsuringAccountability  Developed new Administrative policy describing University’s compliance strategy and expectations (AD 74).  Policy provides protection from retaliation for employees who report crimes.  Established audit trail to ensure complete and accurate crime reporting  Campuses are required to conduct annual self audit.  Compliance Coordinator will conduct a comprehensive audit of each campus every three years (minimum).
    • WhereWe’re Going  Response to ED Program Review Report  Newly EstablishedVAWA Reauthorization (SaVE Act) ImplementationTeam  Developing a ComplianceTracking System  Implemented a “Survival Skills for New Supervisors” program  Working with Legislators to enhance laws like the Clery Act  Possible implementation of standard RMS/CAD system across Commonwealth Campus system
    • Lessons Learned  Over reporting is as “bad” as under reporting  It isn’t always easy getting folks to the training  Although most were eager  A program review is eye opening
    • Lessons Learned  Compliance requires full time professional oversight A good faith effort is not enough  When dealing with Athletics, need buy-in from the highest levels  Records Retention can be a pitfall
    • Lessons Learned  Compliance is an institutional responsibility Not an issue of “if,” but when  Acknowledge and understand overlap withTitle IX  More so with Campus SaVE Act  Need to be proactive with self or peer audit
    • Questions