Summer is Coming: Are Youth Camps Part of Your Clery Compliance Program?
Here are several tips on CSAs, timely warnings and mass notification that will help your youth summer camps comply with the Clery Act.
As summer approaches and UCLA recently announced the temporary closing of a retreat program for alumni families following allegations of hazing and sexual assault, we wanted to re-run this article to emphasize the importance of including school or university-sanctioned summer camps in Clery compliance planning.
ORIGINAL ARTICLE 2/14/23:
It’s winter, and I live in Idaho, which morphs into a pretty chilly place during these months. Since I’m not a fan of feeling like I’m constantly on the precipice of slipping into hypothermia, I spend a fair amount of time thinking about the warmer summer months ahead – and I’m not alone. Do you know who else is starting to spend a lot of time thinking about summer? The folks who run summer youth camps at your college or university.
Early spring semester is often when youth summer camp planning kicks into high gear at institutions of higher education. This is when camps puzzle through the maze of curriculum, logistics, compliance and safety measures related to hosting a youth camp on campus.
Regarding compliance and safety, many institutions have youth protection policies that camps must follow. These policies typically mandate that camp staff pass a background check and complete training related to recognizing and reporting signs of minor abuse prior to beginning work at a camp. However, as the U.S. Department of Education’s (ED) audit of Baylor University’s Clery Act program reveals, this alone is insufficient.
Youth Camp Staff Are Campus Security Authorities (CSAs)
In the Final Program Review Determination (FPRD) ED published regarding their audit of Baylor, youth camp staff are specifically called out as CSAs. Helpfully, ED elaborated on why this designation fit, writing that “the responsibility for the safety of young campers had been entrusted” to camp staff. In Clery-speak, ED is saying that youth camp staff meet the second criteria listed in the regulations for being a CSA:
Any individual or individuals who have responsibility for campus security but who do not constitute a campus police department or campus security department
In the FPRD, ED noted that Baylor did what most institutions do: they provided their youth camp staff with training on minor safety. Importantly, however, ED took issue with the fact that Baylor’s youth camp staff were not “formally identified as CSAs or trained to perform CSA duties.” In other words, providing youth camp staff with training on minor safety only, while important, will not be enough to pass muster in an ED Clery audit.
This finding has clear implications for all U.S. institutions of higher education that host youth camps on campus: your youth camp staff are CSAs and must be identified as such and trained accordingly.
Considerations for Clery Compliance
As someone who has been in charge of youth protection and Clery compliance efforts for a university, I recognize that youth camp staff are a particularly tricky group of CSAs to manage. That’s because these CSAs are highly transitory. They are often students or employees whose normal campus function 363 days out of the year would not make them CSAs, but because they happen to work a two-day youth camp, now are.
Ensuring that your camp staff training program aligns with leading practices and the Clery Act need not be an insurmountable feat and can be accomplished by utilizing your institution’s existing infrastructure.
Consider the following strategies:
- Include whoever oversees youth protection or camps at your institution as a member of your Clery Act Compliance Committee. These individuals will be necessary for advocacy and technical assistance if changes are made to existing youth camp policies, procedures or training.
- Formally identify youth camp staff as CSAs in your institution’s youth protection policy.
- Mandate that all youth camp staff complete both CSA training and minor safety training prior to beginning work for a camp. Generate and maintain documentation of trainings and who was trained. Many camps hold an all-staff meeting just before camp begins to train staff and discuss logistics. This is a great time to provide tailored CSA training to youth camp staff, discuss what safety resources are available, and talk about the downstream effects of what happens after a CSA reports a crime.
How Do Campers Get Timely Warnings?
Speaking of crime reports, this brings us to another camp-related wrinkle to consider: if a CSA reports a crime that triggers a timely warning, how does your institution get that message to your campers?
Now you may be thinking, “Wait a minute. I thought timely warnings only had to be issued to students and employees. Who says they need to be issued to campers, too?” Great question. ED says so.
The Clery Act regulations state that when a Clery Act crime is reported to a CSA or local police, and is determined by the institution to represent a threat to students and employees, the institution must issue a timely warning to its campus community. Who is considered part of your campus community? Enter another illuminating ED FPRD. In the Pennsylvania State University FPRD, ED expounded on the composition of a campus community to include, specifically, campers. In that FPRD, ED wrote that institutions “must issue timely warnings anytime a Clery-reportable crime is reported to a CSA or the police that may pose an ongoing threat to students, employees, or other members of the campus community, including guests such as campers or persons attending concerts or sporting events.”
Considerations for Clery Compliance
Since ED expects timely warnings to be delivered to campers, a logical starting point to consider is whether your institution even has a process in place to be able to accomplish this. Commonly, when an institution issues a timely warning, it does so using blast emails or texts. These methods usually capture a college or university’s students and employees, but not their impermanent campers. For institutions that do not yet have a process in place to disseminate timely warnings to campers, consider the following strategies:
- Connect with whoever oversees youth protection or camps at your institution to see if there is a system that already exists for camps that can be used or expanded to enable the issuance of timely warnings to campers.
- If not, consider alternatives. This could be things like developing a process to enroll campers and/or their parents in an email group for the purpose of issuing timely warnings; putting up signs displaying timely warnings in places campers frequent (food court, dorms, athletic fields); displaying timely warnings using electronic reader boards; developing a process where camp staff pass along timely warning information to campers and/or their parents; posting timely warnings to public-facing institutional social media channels, etc.
- Whatever method of delivery your institution uses to issue timely warnings to campers, make sure it aligns with your institutional policies and that documentation is kept of the policies and their execution.
Youth camps can be a difficult component of an institution’s Clery Act compliance program. Building relationships and having discussions with key stakeholders now – during the initial planning stages and before the pandemonium of summer camp season – will position your institution well to develop the policies and procedures necessary for a safe and compliant camp season. A season, I might add, that I hope arrives sooner rather than later.
Elliot Cox is a school safety analyst for the Idaho School Safety and Security Program, and can be reached at email@example.com.
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