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...
WhereWeWere
Prior to 2011, our compliance approach was…
2011, everything changed
Major Crisis
Dept. of ED at our door ...
WhereWeWere
Initial recommendations included
creating a Clery Compliance coordinator
Selling concept to University
Deve...
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
fun...
Developing Relationships
 Margolis Healy & Associates (MHA)
 Ongoing partnership with MHA
 Clery Center for Security on...
Educating the Campus Community
ATwo-Staged Curriculum:
1. Each Campus Security Authority receives
initial classroom traini...
Increasing Awareness
 Conduct “information sessions” to engage campus community
onClery Act requirements, practices, and ...
Standardizing Procedures
 Forms, templates, and detailed guidance to everyone involved with
reporting crime statistics:
...
EnsuringAccountability
 Developed new Administrative policy describing University’s compliance
strategy and expectations ...
WhereWe’re Going
 Response to ED Program Review Report
 Newly EstablishedVAWA Reauthorization (SaVE Act)
ImplementationT...
Lessons Learned
 Over reporting is as “bad” as under reporting
 It isn’t always easy getting folks to the training
 Alt...
Lessons Learned
 Compliance requires full time professional oversight
A good faith effort is not enough
 When dealing w...
Lessons Learned
 Compliance is an institutional responsibility
Not an issue of “if,” but when
 Acknowledge and understa...
Questions
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Building & Facilitating a Comprehensive Clery Compliance Program

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Building & Facilitating a Comprehensive Clery Compliance Program

  1. 1. Building and Facilitating a Comprehensive Clery Act Compliance Program Stephen Shelow Gabriel Gates Steven Healy
  2. 2. Follow us onTwitter @margolishealy www.slideshare.net/margolishealy
  3. 3. Introduction  Who we are  The University & System  Division of Police & Public Safety
  4. 4. IfYou have a Problem…  …you have a Clery problem  High profile incidents  Congressional intent  Student activism
  5. 5. 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
  6. 6. 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
  7. 7. WhereWeWere Initial recommendations included creating a Clery Compliance coordinator Selling concept to University Developed job description; conducted national search GabeGates selected
  8. 8. WhereWe Are Focused program & approach Consistency – system wide High level support for approach
  9. 9. 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.)
  10. 10. 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
  11. 11. 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.
  12. 12. 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
  13. 13. 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
  14. 14. 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).
  15. 15. 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
  16. 16. 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
  17. 17. 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
  18. 18. 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
  19. 19. Questions

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