Clery Reporting: Whose Job Is It Anyway?
Here’s how you can determine who is (and isn’t) a campus security authority at your institution.
Institutions of higher education are being audited more frequently by the U.S. Department of Education (ED). With the increased frequency of these audits, many have been found to be out of compliance with the Clery Act regarding issues surrounding their efforts, or lack thereof, in gathering crime statistics from the appropriate individuals and offices on their campuses. These individuals are known as campus security authorities (CSAs).
According to the ED’s 2011 Handbook for Campus Safety and Security Reporting, “Even at institutions with a police department on campus, a student who is the victim of a crime may be more inclined to report it to someone other than the campus police. For this reason, the Clery Act requires all institutions to collect crime reports from a variety of individuals and organizations that Clery considers to be campus security authorities.”
A crime should be considered reported when it is brought to the attention of a CSA or local police by a victim, witness, other third party or even an offender. This means that if a parent calls her daughter’s resident assistant (RA) and tells the RA that her daughter was raped, the RA is required to file the appropriate report with the reporting structure identified by the institution. The reporting party and the individuals involved in the crime do not have to be affiliated with the institution for the crime to be reportable. There is no obligation for the police to investigate the report. If the report is made in good faith – meaning that there is reasonable basis for believing that the information is not rumor or hearsay – the incident is reportable.
A campus security authority is:
- A campus police department or a campus security department of an institution: If you have a police or security department, it is obvious that the department meets this requirement. However, have all employees in the department been trained about the fact that they are CSAs? This includes officers, front line supervisors and administrators, such as a lieutenant, captain, assistant chief, victim services coordinator, and the like. Basically, all of the employees in the department, except office support staff, are CSAs. Keep in mind that this includes student employees (other than office staff) who handle tasks like patrolling, monitoring access, or providing a driving or walking safety escort.
- Any individual or individuals who have responsibility for campus security but who do not constitute a campus police department or a campus security department (e.g., an individual who is responsible for monitoring the entrance into institutional property): You should include all individuals who provide security or monitor access to campus parking facilities, or monitor access into a campus facility, such as the library, student union or athletic facility. You should assess the duties of people in these roles on campus. Do they actually monitor access, such as checking IDs or allowing people to enter? If so, they are CSAs. Are they working at an information desk or booth, but are not monitoring access into the facility? If they are not acting as security or monitoring access, they are not CSAs. Do you currently include individuals who act as event security as CSAs? Individuals functioning in the role of event security are campus security authorities, and these include professional staff members, student employees and contract event security staff. Does your institution provide a safety escort service for members of your campus community and/or visitors? If so, those employees or volunteers are campus security authorities.
- Any individual or organization specified in an institution’s statement of campus security policy as an individual or organization to which students and employees should report criminal offenses: Your institution must publish a policy statement that tells the campus community who they should report a crime to on the campus. For many institutions, this will be the campus security, public safety or police agency. However, some colleges and universities don’t have a campus police/public safety agency, and those institutions need to notify the campus community about the individual or organization to which crimes should be reported. This may include directing them to report crimes to the local law enforcement agency. The institution may also want to consider whether or not an individual or organization on the campus should be identified for students and employees to report the crime directly to a representative of the institution. (Receiving crime information quickly and directly will be important for assessing whether or not a timely warning should be distributed).
- An official of an institution who has significant responsibility for student and campus activities, including, but not limited to student housing, student discipline and campus judicial proceedings. An official is defined as any person who has the authority and the duty to take action or respond to particular issues on behalf of the institution: This is the most challenging area because the concept of “significant responsibility for student and campus activities” is quite broad. Official responsibilities and job titles vary significantly at each campus, which is why ED says they don’t provide an all inclusive list of specific titles in the regulations. The handbook states, “To determine specifically which individuals or organizations are campus security authorities for your institution, consider the function of that individual or office. Look for officials (i.e., not support staff) whose functions involve relationships with students. If someone has significant responsibility for student and campus activities, he or she is a campus security authority.
Assess CSAs on a Yearly Basis
It is critical for each institution to conduct an annual assessment of the roles and functions of all of their its members to determine whether or not anyone should be added to or removed from the list, resulting from any changes to their job descriptions or responsibilities.
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