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Just in Time: Clery Act Tips Before Fall 2019

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Hear from Clery Act experts Laura Egan, senior director of programs for the Clery Center; Steven Healy, CEO and co-founder of Margolis Healy; and James Moore, senior advisor for Clery Act compliance and campus safety for the U.S. Department of Education who discuss Clery Act tips in time for fall 2019. Laura, Steven, and James share their experiences and perspectives regarding the most critical issues in Clery Act compliance, with particular focus on those requirements related directly to the ASR/AFSR. They cover areas such as the policy and procedure requirements, distribution processes and notices, and challenges related to collecting and classifying crimes.

Published in: Education
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Just in Time: Clery Act Tips Before Fall 2019

  1. 1. Campus Public Safety Online Just in Time: Clery Act Tips Before Fall 2019
  2. 2. • Oversees the development and execution of training and technical assistance projects, programs, and resources at Clery Center. • Presents nationally and provides individualized support on compliance with and implementation of Clery Act requirements, campus safety, compliance, and gender based violence and discrimination. 2 Laura Egan • CEO and Co-Founder of Margolis Healy & Associates. • Nationally recognized expert on campus public safety, Title IX and the Clery Act. • Former Director of Public Safety/Chief of Police at Princeton University, former Chief of Police at Wellesley College, and former Deputy Director of Public Safety at Syracuse University. • Subject-matter expert for the U.S. Depts. of Education and Justice. Steven J. Healy • Senior Advisor for Clery Act Compliance and Campus. Safety, U.S. Dept. of Education • Serves as the Federal Government’s leading expert on the Clery Act, the Drug- Free Schools and Communities Act, and other campus safety and crime prevention initiatives. • Leads the Department’s Clery Act training, technical assistance, and outreach initiative. James Moore
  3. 3. Campus Security Authorities James Moore 3
  4. 4. Themes • Campus safety & crime prevention are always job #1 • Compliance is the floor • Compliance is primarily about doing the right things well • Compliance is not a “twisted test” • Do not “go it alone” - You need a team - Think “Ocean’s 11” • While we are at it, let’s “protect the brand” • Culture attracts character and character shapes the culture • We cannot be our best when we operate from of fear • Relax a little • Make an impact 4
  5. 5. Campus Security Authorities • Members of a campus law enforcement or public safety entity • Any individual who has responsibility for campus safety but is not part of a campus law enforcement or public safety entity (hall monitors; parking attendants) • Any institutional official with significant responsibility for student and campus activities • Any other individual to whom students and employees are directed to report crimes • Actual professional & pastoral counselors are exempt Note: Special considerations for institutions specializing in counseling or affiliated with churches/religious orders 5
  6. 6. Likely Categories of CSAs On Your Campus 6 Campus Leadership and Senior Administrators Residence Life Staff, including RAs Athletic Directors and Coaches Victim Advocates and Ombudspersons Campus Law Enforcement and Public Safety Professionals Student Life and Student Organizations Staff, including Student Leaders Title IX Coordinators and Staff
  7. 7. What’s Happening on Your Campus? • How many CSAs does your campus have? • How does your school notify CSAs of their reporting responsibilities? • What evidence does your school retain to show that CSAs have been notified of their reporting responsibilities? • Do CSAs receive any training? If so, how often? Is it reviewed for accuracy? How is participation documented, if at all? 7 Discussion
  8. 8. The Key: Administrative Capability To participate in any Title IV program, an institution must demonstrate that it is capable of adequately administering the program under the standards established by the Secretary, including: • Employing “an adequate number of qualified persons” • Ensuring that programs are administered with appropriate “checks and balances” in a system of “internal controls” • Implementing written procedures that document the responsibilities of institutional officials with respect to the “preparation and submission of reports to the Secretary” 8
  9. 9. Demonstrating Administrative Capability The key to Admin Capability is to design and implement a system of policies, procedures, training programs, and systems that will provide reasonable assurance that required actions will be taken and that mechanisms are in in place to detect deficiencies before they become systemic or result in catastrophic failure. Among other elements, an adequate Clery compliance program will include: • Detailed procedures for preparing and distributing an accurate and complete ASR • Substantive processes for identifying and classifying the institution’s “Clery Geography” • Comprehensive procedures for identifying CSAs and notifying them of their responsibilities • Reliable methods for requesting and collecting information about Clery-reportable crimes from institutional CSAs and local law enforcement agencies • Consistent standards for providing a valid response to the Department’s annual crime statistics survey 9
  10. 10. Mining Your Clery Data -- Ensuring Accurate Disclosures Steven J. Healy 10
  11. 11. Data Matters • Importance of Accurate Data • Who? • The Pitfalls • Collaborating Across Campus 11
  12. 12. 15-Year Fine Trend by Violation Type 12 $52,500.00 $110,000.00 $140,625.00 $203,750.00 $232,500.00 $345,000.00 $400,000.00 $707,625.00 $948,125.00 $1,152,989.00 $1,190,250.00 $3,310,500.00 VAWA Procedures * - $52,500 TW -Policy - $110,000 Administrative capability - $140,625 TW/EN - Implementation - $203,750 Crime data - Geography - $232,500 Daily crime log/fire log - $345,000 Crime data - VAWA -$400,000 DFSCA -$707,625 ASR Policy statements - $948,125 Crime data - Sources/Collection -$1,152,989 ASR/AFSR -Publish/Distribute - $1,190,250 Crime data - Classification/Disciplinary Referrals - $3,310,500 Crime data in some fashion accounts for 58% of all $ fined.
  13. 13. Data Matters • Analysis of accuracy of classification and count • Implied in Title IV PPA: “checks and balances” • Best undertaken by competent reviewers • Consistently uncover serious problems with data • ED expects you to maintain an “audit trail” – “Cradle to Grave” 13
  14. 14. Data Analysis & Verification Process 1. Identify Data & Data Locations All reports, complaints, activity, etc. All offices: CPS, Student Conduct, Res. Life, TIX, HR, CSA forms, On- line reporting systems Focus on reports that may mask reportable incidents. Ex. Information, Investigation, Assist Other Agency, Suspicious Activity, etc. REMEMBER: “A crime is “reported” when it is brought to the attention of a CSA or the local police, by the victim, witness, other 3rd party, or the offender.” 2. Identify & Train your Clery Liaisons Provide formal trainingCapable of independently classifying and counting Clery Act crimes 3. 2-Step Classify & Count/Monthly Reconciliation 1. Real time Departmental Classification 2. Collaborative Verification 4. Clery Coordinator aggregates Departmental data into consolidated database Don’t forget TW determinations Remember Jim’s points about the importance of CSA processes Clery Liaisons meet monthly to review all “potential” Clery reportable incidents and verify Departmental analysis
  15. 15. Data Matters 15
  16. 16. Data Matters – Summary • Start with all reported incidents/activity; this ensures appropriate checks and balances • Trust, but Verify – You are verifying the accuracy of all classifications, including LLV & DLV – THINK: STRENGTH in NUMBERS • Once verified, save this information in a Clery Data Audit trial • Classify and count as you go vs. performing this complex step at the beginning of the calendar year – Also reinforces the notion of pan-institutional responsibilities • Document this process in your Clery Act Compliance Policy 16
  17. 17. Starting and Ending with the ASR Laura Egan 17
  18. 18. Annual Security Report Overview Distribution to Current and Prospective Students/Employees Crime Statistics Required Policy Statements 18
  19. 19. Policy Policy Statement Practice 19
  20. 20. Before We Move Forward… • Creation of ASR ensures policies and processes are in place • “Say what you do; do what you say.” • Who is at the table? • Does it reflect what actually takes place? • Is it a useful document? 20
  21. 21. General Areas Governing Issuance of Policy Statements 1. Compiling the Annual Security Report 2. Security Of and Access to Campus Facilities 3. Law Enforcement & Jurisdiction 4. Reporting Crimes and Other Emergencies 5. Timely Warnings & Emergency Notification and Evacuation 6. Security Awareness Programs 7. Crime Prevention Programs 8. Drug, Alcohol, & Substance Abuse 9. Dating Violence, Domestic Violence, Sexual Assault, and Stalking Policies 10. Student Disciplinary Proceedings Results 11. Sex Offender Registration Policy 12. Missing Student Notification Procedure 13. Fire Safety Report 21
  22. 22. Crime Presentation: Three Required Elements Geographic Area On-campus property - Student housing facilities Noncampus property Public property Type of Crime Clery Act crimes Arrests & disciplinary referrals Calendar Year Year crime was reported Three most recent years 22
  23. 23. Deadline? Who? How? Format? Publication & Distribution: Four Components 23
  24. 24. Start and End with the ASR • ASR captures most aspects of Clery compliance • Understanding the ASR leads to a high level understanding of the Clery Act • Diving deeper into each aspect of the ASR enables greater understanding of Clery Act requirements 24
  25. 25. 25 Laura Egan legan@clerycenter.org 484-584-4253 Steven Healy shealy@margolishealy.com 609-468-8326 James Moore james.moore@ed.gov 215-656-6495 Stay Connected With Us
  26. 26. www.bja.gov www.margolishealy.com www.nccpsafety.org info@nccpsafety.org 1.866.817.5817

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