A practice to avoid these errors includes identifying all locations through a review of maps, contracts and verbal/oral agreements. For example, a fraternity house may be controlled by the fraternity but is located on land owned by the institution on the confines of the campus. In this instance, the property would be reported as on-campus. Administrators should also evaluate programs that occur as part of study-abroad programs. An annual evaluation of the locations of these programs and what is reportable is prudent.
Separate campuses consistently pose a challenge for colleges and universities. If a campus is not reasonably contiguous to an institution and has an organized program of study, one person or more on-site as an administrator, and the institution owns or controls the space, it is considered a separate campus and should be reported as such with a separate Annual Security Report.
2. Lack of or Inadequate Policy Statements
The Clery Act requires the publication of an Annual Security Report each October that includes reportable crime statistics and policy statements. The policy statements serve as summaries for campus policies around crime prevention and reporting protocols.
A common finding of ED program reviews includes inadequate or lack of policy statements. The areas where most deficiencies are recognized are for timely warnings, reportable crimes, confidential reporting, sexual assault policies, crime prevention programs and relationship with local law enforcement.
To effectively build policies, campus administrators must convene regularly to ensure that statements include all components of federal law; furthermore, campus administrators must determine if the implementation of the policy is realistic.
3. Failure to publish and share an Annual Security Report
The Clery Act requires institutions that receive Title IV funding to publish and distribute an annual security report (ASR) to all current and prospective students and employees. This report includes crime statistics for the three preceding calendar years along with summary policy statements in areas such as sex offense prevention and response, timely warnings, and emergency notification.
The policy statements are summarized above and the Clery Center provides training and checklists supporting the production of this document.
4. Inadequate Methods to Collect Crime Statistics
“Campus Security Authority” is a Clery-specific term that identifies individuals responsible for providing crime statistics to campus security, public safety or police. CSA refers to four distinct groups of individuals on a campus: campus police, public safety or security; any individual responsible for monitoring access to buildings and other spaces; any individual or office where a crime is reported to; and an official at the institution who has significant responsibility for student and campus activities.
Many institutions fall short in notifying employees and staff that they are Campus Security Authorities and training them on this role. Campus police and public safety departments cannot be the sole stewards of these issues. The approach will only succeed if it is both top-down and bottom-up by engaging their boards of trustees or regents, president’s offices, students and administrators to fully address campus crime, and to build safer campus communities that do not tolerate sexual violence.
Alison Kiss is Executive Director of the Clery Center for Security On Campus. She has contributed to textbooks on campus crime and sexual violence and has spoken nationally and internationally on these topics. She is currently completing a doctoral degree in higher education leadership at Northeastern University with research interests in leadership and compliance with Federal law. For more information about the Clery Center, visit www.clerycenter.org.