The document provides an overview of the Clery Act and tips for compliance before the fall 2019 semester. It introduces several experts on the Clery Act, including Laura Egan, Steven Healy, and James Moore. They discuss key topics like identifying campus security authorities, ensuring accurate crime data collection and reporting, demonstrating administrative capability, and properly creating and distributing the annual security report with the required policy statements and crime statistics. The experts emphasize the importance of collaboration across departments to maintain Clery Act compliance.

1. Campus Public Safety Online
Just in Time: Clery Act Tips Before Fall 2019

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. Campus Security Authorities
James Moore
3

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. 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. 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. 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?
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Discussion

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. 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. Mining Your Clery Data --
Ensuring Accurate Disclosures
Steven J. Healy
10

11. Data Matters
• Importance of Accurate Data
• Who?
• The Pitfalls
• Collaborating Across Campus
11

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. 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. 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. Data Matters
15

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. Starting and Ending with the ASR
Laura Egan
17

18. Annual Security Report Overview
Distribution to Current and
Prospective Students/Employees
Crime Statistics
Required Policy Statements
18

19. Policy
Policy
Statement
Practice
19

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?
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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. 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
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23. Deadline? Who? How? Format?
Publication & Distribution: Four Components
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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
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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. www.bja.gov www.margolishealy.com
www.nccpsafety.org
info@nccpsafety.org
1.866.817.5817