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Building & Facilitating a Comprehensive Clery Compliance Program
This document outlines the steps taken by a university system to build a comprehensive Clery Act compliance program after facing non-compliance issues and a Department of Education review. Key steps included hiring a dedicated Clery Act coordinator, identifying and training campus security authorities, standardizing crime reporting procedures, increasing community awareness, and establishing accountability measures like annual self-audits. The program aims to ensure accurate and consistent crime reporting across the university's 23 campuses through education, policy, and oversight.
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Building & Facilitating a Comprehensive Clery Compliance Program
- 1. Building and Facilitatinga Comprehensive Clery Act Compliance Program Stephen Shelow Gabriel Gates Steven Healy
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- 3. Introduction Who weare The University & System Division of Police & Public Safety
- 4. IfYou have aProblem… …you have a Clery problem High profile incidents Congressional intent Student activism
- 5. The Price ofNon-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. 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. WhereWeWere Initial recommendations included creatinga Clery Compliance coordinator Selling concept to University Developed job description; conducted national search GabeGates selected
- 8. WhereWe Are Focused program& approach Consistency – system wide High level support for approach
- 9. A Holistic Approachto 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. Developing Relationships MargolisHealy & 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. Educating the CampusCommunity 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. 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. 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. EnsuringAccountability Developed newAdministrative 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. WhereWe’re Going Responseto 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. Lessons Learned Overreporting 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. Lessons Learned Compliancerequires 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. Lessons Learned Complianceis 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
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