5 ways to enhance Clery compliance

1. Clery Act Update
iaclea Southeast & Southwest
Regional Conference
Steven J. Healy
Margolis Healy & Associates

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3. Agenda
• Making the Case
• Clery Act 101
• 5 Ways to Immediately Enhance
Compliance
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4. The Landscape
A sea change –
• Renewed focus on the issues of sexual
and gender violence
• Activism by students, faculty, others
• Survivor courage
• Evolving legislation (Clery & TIX)
• REALITY – The world is FLAT
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5. A Not So Quiet Storm
• Clery Act is official home for most campus safety &
security legislation
• Aftermath of Virginia Tech tragedy – Clery
amended
• Campus SaVE Act amends Clery; changes
effective 2014
• Anti-Bullying efforts may land in Clery
• OCR Focus on Title IX and overlap with Clery
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6. No – this is a TSUNAMI!
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7. © Margolis Healy & Associates, LLC

8. The Prevention Lens
COMPLIANCE IS IMPORTANT, BUT
PREVENTION AND RESPONSE IS
MORE IMPORTANT
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9. ED – Coming Soon to a Campus Near You!
• If you have a problem, you have a PROBLEM!
• ED proactively focuses on campus incidents and
local, regional, national headlines
 Virginia Tech (Timely Warning Reports)
 Bowie State University (Document Request Only)
 Morgan State University (Document Request Only)
 Penn State (Program Review Underway)
 University of North Carolina – CH (Program
Review Underway)
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10. Clery Act 101
• 1986:
• 1988:
• 1990:
• 1992:
• 1994:
• 1998:
• 1999:
• 2000:
• 2002:
• 2005:
• 2008:
• 2009:
• 2011:
• 2013:
Jeanne Clery murdered at Lehigh University
Pennsylvania Act 73
Federal Crime Awareness & Campus Security Act
Campus Sexual Assault Victims’ Bill of Rights
Campus Security Act Regulations
Higher Education Act Amendments
Clery Act Regulations Issued
Campus Security Statistics Website
Campus Sex Crimes Prevention Act
ED’s Clery Handbook Published
Higher Education Opportunity Act 2008
Final Campus Safety Regulations
Handbook for Campus Safety & Security Reporting
Campus SaVE Act
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11. What is this thing called “Clery?”
• A consumer rights bill
• An institutional responsibility
• Not JUST campus public safety
• Campus-wide collaboration and
cooperation critical to success
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12. 5 Ways to Enhance Compliance
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13. 5 Ways to Enhance Compliance
1. Formally appoint a Clery Act Compliance
Coordinator.
• Processes, on-going data gathering and campus
collaboration, demand focus
• At a minimum, 50% of time dedicated to Clery
• Coordinator leads Clery Act Committee
 Formally chartered group of administrators
should guide the institution’s Clery compliance
activities.
 Size doesn’t matter
© Margolis Healy & Associates, LLC

14. 5 Ways to Enhance Compliance
2. Review your required policies.
•
Ensure policies and policy statements are
updated and represent your current practices
•
Review at least annually
•
Emphasis on policies governing Timely
Warning Reports, Campus Sexual
Assault, Domestic/Intimate Partner Violence &
Stalking Prevention Programs, Emergency
Notifications and Missing Students
© Margolis Healy & Associates, LLC

15. 5 Ways to Enhance Compliance
3. Identify and train your campus security authorities.
•
Use org. chart to identify those officials who have
significant responsibilities for students and
campus activities. Deans, directors, and coaches
are a start.
•
You likely have hundreds, possibly thousands
•
Conduct in-person training for Tier 1/Tier 2 CSAs
•
On line for others
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16. Educating the Campus Community
Two-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.
© Margolis Healy & Associates, LLC

17. Increasing Awareness
•
Conduct “information sessions” to engage
campus community on Clery 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.
© Margolis Healy & Associates, LLC

18. 5 Ways to Enhance Compliance
4. Fail proof your crime and arrest/referral data
collection process
•
Flowchart your process for collecting data from
required sources
•
Are there offices that have disciplinary systems
that you’re not aware of, or have confusion
over, what has to be reported?
•
Do you have the necessary forms to facilitate
data collection?
•
Test your system often
© Margolis Healy & Associates, LLC

19. 5 Ways to Enhance Compliance
5. Identify and track all of your safety awareness
and crime prevention programs.
•
Give credit where credit is do; many ASRs
omit the programs offered by other campus
departments.
•
Maintain an inventory of all campus programs
and update as needed.
•
Ensure you list both type and frequency of all
programs in your ASR.
•
Don’t go to MSU
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20. 5 Ways to Enhance Compliance
6. Prepare for the Campus SaVE Act
•
Develop your policies & policy statements
•
Ensure data collection processes for new
areas
•
Revise Grievance Procedures
•
Develop & implement training and education
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21. Campus SaVE Act Challenges
• Requires your IMMEDIATE attention
• Collaboration & Coordination are KEY
• Programming Resources
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22. 5 Ways to Enhance Compliance
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23. Thank You!
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24. Contact Information
www.margolishealy.com
866-817-5817
www.slideshare.net/margolishealy
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