By now, most colleges and universities have taken steps to form a threat assessment team. Threat assessment teams investigate a wide range of concerning behaviors and potentially dangerous situations, including threats made by students, employees, faculty members, and others in the community. Of course, threat assessment teams cannot take action unless they are notified anytime someone on campus or in the community observes or learns of a threat of violence or a situation that appears to be threatening.
Threat assessment teams typically include 5-10 members and should be multi-disciplinary, including representatives from college administration, law enforcement, mental health, and legal counsel. Taking on the role of a threat assessment team member is an added responsibility and an important obligation. Lessons learned reveal the key to keeping threat assessment teams from becoming overwhelmed is to ensure they have the right processes outlined and the right tools to collect the dots, assess the dots, connect the dots, intervene and prevent incidents and tragedies.
A recent survey revealed 70 percent of campus threat assessment teams are meeting once or twice a week to review current situations. With mounting job responsibilities, finding time to get together in person and discuss can be difficult.
Several colleges in Virginia have implemented Awareity’s TIPS (Threat Assessment, Incident Management and Prevention Services) Platform to help them manage and coordinate their threat team efforts, saving valuable time and resources while improving collaboration and information sharing.
When an incident report concerning a threat on or to campus is submitted, the first task of a threat assessment team is to collect as much information as possible to determine the potential for risk. Threat cases each requires an individualized approach and the more information that can be gathered the better. Gathering this information may include interviewing the individuals/witnesses involved, speaking with faculty/friends, and reviewing social media, or conducting a formal law enforcement investigation. Keeping track of the steps taken during this investigation and coordinating all actions and communications between team members is where TIPS delivers valuable advantages.
No longer do threat assessment teams need to find a time/place for everyone to gather, but team members can easily login and document their findings and case notes, set tasks for other team members, etc. and all other team members can review the investigation and ongoing updates in real-time, rather than waiting for their next meeting. All actions are date/time stamped, providing legal-ready documentation and accountability, while also ensuring appropriate steps are taken to most effectively intervene and prevent a situation from escalating into something much worse, more expensive and more embarrassing.
Equipping your threat assessment team to communicate effectively utilizing a secure centralized platform is critical in connecting the dots. Lessons learned reveal over and over how organizations failed to connect the dots and failed to prevent preventable incidents and tragedies. A centralized platform like TIPS allows all threat assessment team members to search related incident reports involving one or more individuals, review previous reports, investigations, and actions, and assess a more comprehensive overall pattern of behavior. As we learned from the tragic Virginia Tech massacre, many individuals observed concerning behaviors with the student who carried out the attack, but these concerning behaviors were not routed to one central place where multiple reports could be connected and the seriousness of the threat(s) could have been accurately identified.
Rappahannock Community College’s VP for Administration, Kim McManus, shared, “We know that even though we are a smaller community college, we are not immune to threat. TIPS has helped our threat assessment team establish effective procedures for investigating all potential risks. Providing proper documentation used to be a difficult task, but TIPS allows us to be more efficient and easily track team investigation notes in one place – no more spreadsheets.”
Threat assessment record-keeping can be a difficult issue for threat assessment teams because threat records may include sensitive information or even criminal records that do not fit into previously established conventions, like student records systems. In fact, if your campus is currently placing threat assessment records in your student conduct or student information system (SIS), you may be inadvertently putting this information at risk to unwanted exposure and liabilities.
This common misunderstanding about where to place and maintain threat assessment records is a very serious awareness disconnect with FERPA and is costing schools and colleges in numerous ways. Not only are threat assessment records put at risk in a SIS, some threat assessment team members are not putting key information into the SIS which means other threat assessment team members are not seeing all of the right information and not able to make the right decisions. FERPA clearly identifies “law enforcement unit” records can and should be kept separate from SIS records.
The Virginia Threat Assessment State Law Guidance also recommends threat assessment teams keep their threat assessment records separate from student records and treat them as “law enforcement unit” records. Threat assessment records should only be accessible to authorized threat assessment team members and/or “law enforcement unit” personnel.
Another validation for keeping threat assessment records in a secure centralized platform is the American National Standards Institute (ANSI) Workplace Violence Standard, co-developed by ASIS and SHRM. The ANSI Workplace Violence standard clearly states in their threat management protocol, that organizations should provide secure, “need to know” and anytime access to a centralized record keeping platform.
Threat assessment team members can of course still access student information systems (SIS) to locate information like class schedules, contact information, etc. and share this information as needed within a platform like TIPS, but keeping the actual investigation details and threat assessment records separate from your SIS is vital. Once the threat assessment process has been concluded or a resolution has been determined, i.e. suspension from campus or a student conduct violation, the resolution can/should be recorded in the SIS, but all investigation and actions taken prior to resolution should only be discussed between team members and remain in the secure centralized platform.
A second FERPA awareness disconnect that was exposed in the Virginia Tech Review Panel Report involved what student records can and should be shared with others. When “law enforcement unit” records are not maintained in a SIS, they are not under the jurisdiction of FERPA. However, education records and personally identifiable information contained in education records do not lose their status as educational records and remain subject to FERPA while in possession of the law enforcement unit. And FERPA neither requires nor prohibits the disclosure by any educational agency or institution of its law enforcement unit records.
Of course connecting all the right dots means we need a better way to collect the dots first. How can threat assessment teams ensure they are receiving incident reports? TIPS is a comprehensive prevention platform and offers a truly anonymous incident reporting option. A TIPS incident reporting button is easily and strategically placed on one or more websites allowing anyone on the campus or within the community to easily, securely and anonymously report concerning behaviors using any web-accessible device. Campus threat assessment teams can determine what types of incidents should be reported (sexual misconduct, threats to harm, weapons, drug/alcohol abuse, self-harm/suicide threats, suspicious persons, etc.) and can make sure each incident type is customized to ask the right questions so they can receive the right information.
Thomas Nelson Community College, the first Virginia community college campus to implement the TIPS prevention platform in 2012, had previously established a standard web-based reporting form, but the customization features available in TIPS provided significant advantages.
“Being able to determine what types of incidents could be reported and design the forms and questions based on our current procedures made the transition to TIPS simple. And the way in which reports from different locations and incident types could be directed to the appropriate staff, helped us ensure the right people were being notified so immediate and proactive actions could be taken,” said Chief Kelvin Maxwell.
In addition, to Maxwell, Thomas Nelson’s Threat Assessment Team includes the Vice President for Finance and Administration, Human Resources manager, campus police and student counseling staff. General Counsel is also added to specific reports when needed. With TIPS third-party resources law enforcement, mental health, compliance, etc. can become involved and added to individual reports in the system, if, and only when, their guidance is requested.
Campus-wide awareness and education regarding incident reporting of concerning behaviors are critical – all resident advisors, mental health counselors, academic advisors, faculty members, etc. need to understand that all threats and concerning behaviors should be communicated to the threat assessment team. Ongoing awareness and reminders for students, faculty and staff should emphasize how they play a very important role in keeping their campus safe and helping individuals in distress, whether or not a direct threat has been made.
At the beginning of the fall semester, Germanna Community College posted several TIPS Awareness Posters (provided by Awareity) around campus with examples of the different behaviors that can and should be reported via TIPS.
“Students really appreciate that we are taking extra steps to involve them in safety efforts on campus. They really are our best eyes and ears on campus.TIPS allow anyone associated with the college community to come forward and anonymously share information regarding concerning behaviors with us,” said Pam Frederick, Dean of Student Development at Germanna. “The information is immediately communicated to our threat assessment team and proactively investigated so we can prevent the situation from escalating.”
Once an investigation is determined to be “resolved”, it is also important to follow-up and monitor at-risk individuals and situations on an ongoing basis. The follow-up process may be as simple as checking in with the student (or parents, roommates, counselor of the individual involved) periodically and ensuring the situation is not escalating. TIPS provides a valuable reminder tool that ensures these follow-up actions are taking place and no student/individual slips through the cracks.
Other community colleges are also using TIPS to help all Campus Security Authorities (CSAs) report required Clery Act categories (hazing, hate crimes, stalking, assault, etc.). Once the incident reports are submitted, they are easily reviewed for reporting requirements and to ensure compliance with numerous other Clery requirements. Third-party security staff and guards can also utilize the platform to keep track of all of their security incidents (vandalism, trespassing, theft, disorderly conduct, etc.).
Southside VA Community College and Wytheville Community College (and others too) will also be launching the TIPS prevention platform for their campus communities this year, as the evidence and successes from other colleges clearly show TIPS is saving lives, futures, reputations and budgets.
About the Author:
Katie Johnson is Vice President of VP Marketing and Client Services for Awareity. After graduating from the University of Nebraska – Lincoln in 2005, Johnson joined Awareity and has helped grow and expand their services, including the introduction of the award-winning web-based prevention platform, TIPS, in 2010. She leads Awareity’s implementation and client support team and enjoys strategizing with clients to generate creative solutions for client challenges and requirements. Gathering client feedback and lessons learned is also key as Johnson works directly with the Development team, evolving the TIPS platform and creating innovative and intuitive product features to help clients improve ongoing efficiencies. To learn more about Awareity’s TIPS platform and the award-winning Cawood Assessment Grids, please visit www.awareity.com.
