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.

To find all of the individuals on campus whose functions involve relationships with students, I suggest that institutions assess all employees who have the following roles and duties:

  • Significant interaction with students and/or campus activities
  • Informal or unofficial mentors to students
  • Member in an office or a committee to whom students are instructed to report or discuss crimes, allegations of crimes and other troubling situations
  • Oversee disciplinary processes or procedures.

It should be noted that CSAs do not have to be paid employees. They can be volunteers serving in one of the roles.

The number of CSAs at your institution depends on the number of individuals or organizations involved in security or that have significant responsibility for student and campus activities, not on t
he size of your institution. Also, if a crime is reported to a CSA, it should be reported to the reporting structure identified by the institution, regardless of whether the reporting party wants to file a report with law enforcement or press charges. 

Mistakes That One Audit Uncovered
In a recent (preliminary) program review report, an institution was found to be in non-compliance because the “college did not gather statistics for incidents of reportable crimes from certain institutional sources in a manner sufficient to produce an accurate and complete Annual Security Report (ASR) in accordance with the Act. The failure resulted in additional instances of under reporting and miscoding. Specifically, there was insufficient coordination and communications between the campus safety office and student affairs/residence life, which resulted in deficient incident reports and disciplinary referral data. Some of the weaknesses identified include the following:”

  1. “Resident advisors were trained not to inquire about where alcohol was obtained when students were found to be drinking in residence halls. This questioning was customarily the responsibility of the residence directors and was usually asked as part of the judicial process. If any information was obtained as to who provided the alcohol, an instance that would be an additional law violation, there was no process for ensuring that this information was included in the annual campus security reports.” This assumes that every incident of providing alcohol to a minor actually occurred in one of the Clery geographic areas (on campus, noncampus or public property). If the alcohol was provided to the minor off campus, the violation of the law would not be reportable, as it didn’t occur within the reportable Clery geography.
  2. “Clery reportable incidents were reported to resident assistants. However, the college did not have adequate procedures in place to ensure that these incidents were included in the crime statistics. This part of the finding is supported by three incident reports, all of which should have been counted as burglaries. All of these reports were initially reported on an Office of Residence Life form, but none of these incidents appear on the crime log or appear to be included in the statistics for 2007 even though one incident carried a notation that it was reported to the director of security.”  When a CSA reports a crime to the security, public safety or police department, that department is responsible for adding the crime to the crime log within two business days. This includes judicial referral information that is forwarded to one of those departments at the end of the calendar year.
  3. “Some reports written by resident advisors are written with insufficient detail to allow determination of whether a Clery reportable crime occurred. This part of the finding is supported by an incident report, which details an argument between roommates. The report mentions that a boyfriend of one of the individuals took out a knife, but there is no other description of the weapon and there is insufficient detail to determine whether this should be a weapons law violation.” Many of us have always believed that the CSA was responsible for simply reporting what was reported to them, but this finding of non-compliance suggests that the CSA is responsible for “interviewing” the reporting party in an attempt to find out the details of what occurred.

Train CSAs on Questions They Should Ask
ED expects all CSAs to gather details, or at least ask questions that would provide sufficient detail to properly classify the incident. (See How to Properly Classify Incidents on this page.) This means CSAs need to ask some specific questions and document the responses or lack thereof. The CSAs obviously can’t force the reporting party or the accused to answer those questions, but according to this program review report, CSAs are obligated to ask certain questions.

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