5 Steps to Consider When Reviewing the New Clery Act Handbook
Here are some action plans for schools dissecting the changes in the new version of the Handbook for Campus Safety and Security Reporting.
3. Review the Department’s examples of individuals who are typically campus security authorities (Chapter 4, 4-3 – 4-4). Institutions collect statistics from individuals called campus security authorities (CSAs), which include campus police or security, individuals responsible for security, individuals designated by the institution to receive crime reports, and officials of an institution with significant responsibility for student and campus activities.
Although CSAs are determined by function and can vary from institution to institution, the Department does provide a list of who typically falls within this role and the updated list may include roles institutions didn’t previously consider to be CSAs, such as an ombudsperson, a director of a campus health or counseling center, victim advocates, and members of a sexual assault response team.
Although some of these positions may have confidentiality under state law, they are still able to function as CSAs because, in most cases, it’s possible to fulfill their responsibilities while maintaining victim confidentiality, as they are required to report non-identifiable information such as the nature of the crime, the date and time it occurred, the date and time it was reported, and the location. Regardless, CSA reporting may lead to other actions on the campus, such as the issuance of a timely warning, so it’s important to train these individuals on their responsibilities as a CSA and how to compassionately communicate their role and set expectations with someone making a report. This may also be a good time to revisit timely warning and emergency notification policies and procedures.
4. Read Chapter 8 of the Handbook. The 2013 amendments to the Clery Act most significantly impact prevention and response to crimes of sexual assault, domestic violence, dating violence, and stalking. Chapter 8 breaks down these requirements to more clearly illustrate what information and practices the institution must include within campus policies and then reflect within their annual security report. (Of course, it’s important to read all the chapters – but especially this one.)
5. Document, document, document. More than ever, the Handbook reinforced the need to document reports and decisions. Does your institution use a CSA reporting form? How are timely warning decisions documented? Do you retain annual security reports and all supporting records for at least seven years? Chapter 9 (9-11) reviews some of the documents to keep. Think about if you were no longer at your institution – would someone new know what decisions you made and why you made them?
For more information on some of the Handbook’s most significant updates, view the Clery Center’s “Clery Handbook Highlights” webinar, featuring Clery Center staff as well as the senior advisor for Clery Act compliance at the United States Department of Education, James L. Moore, III, or contact the Clery Center at info@clerycenter.org.
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