The Role of a Clery Compliance Manager
Stakeholders from a wide variety of campus disciplines must collaborate with the person designated to do this job so that accurate crime and incident statistics are reported. Here’s how Penn State does it.
With more and more institutions of higher education coming under scrutiny by the U.S. Department of Education for possible Clery Act violations, it’s not surprising that 77% of higher education respondents to Campus Safety magazine’s latest survey say their campus now has a designated Clery compliance officer. Here’s how Penn State’s compliance manager, Gabe Gates, approaches his job.
Training Must Be Ongoing
Managing the Clery compliance efforts of Penn State’s 23 campuses is a tall order considering the system has about 3,000 campus security authorities (CSAs). Those individuals include both sworn police and non-sworn security officers, as well as athletic department personnel, faculty advisors, RAs and others.
“Most of these people probably didn’t begin their careers thinking that someday they were going to be in a position where they would have to report crime,” Gates says. “Educating not only our CSAs but the university in general as to what they are required to do, why they are required to do it and how they do it is a challenge.”
Fortunately, he has the support of top administrators. Penn State has a Clery committee made up of 12-15 staff members such as the system’s Title IX coordinator, vice presidents of student affairs, student conduct and residence life, as well as general counsel and human resources. Also, compliance efforts are helped by the fact that most Penn State rank-and-file CSAs understand the critical nature of the Clery Act.
“We’ve been very lucky in that everyone has understood the importance of their task and have been willing to cooperate,” he says.
At Penn State, CSAs are required to go through their initial Clery training in a classroom setting and then follow up with an annual online refresher course. Gates believes that without such training, most CSAs would have difficulty understanding their responsibilities under the law.
“The language of the Clery Act can be confusing for the CSA who has never had this responsibility before, so it’s really important for us to get in front of them,” he says.
Another important aspect of Gates’ duties is fielding calls from CSAs, department heads, police and security departments, and others seeking clarification on how to report a crime under Clery. He also encourages compliance and keeps everyone up-to-date on Penn State’s status via meetings, letters and E-mails.
Partnership with Title IX Coordinator Is Vital
Because the Clery Act has so many similarities with Title IX, Gates also works very closely with Penn State’s Title IX coordinator and deputy coordinators.
“Both offices have to understand the requirements of the other office, and it is a collaborative effort,” he says. “Some [of the requirements of Clery and Title IX] are a bit contradictory. For example, under Clery, we might be able to accept the report of a sexual assault and keep it completely confidential, where with Title IX, we might not have that ability in every case.”
Penn State also allows for anonymous reporting by CSAs, not just victims.
“I think that has eliminated some of the fears people may have about going to police or reporting a crime in person,” says Gates. “We don’t want any type of fear to prevent them from reporting something.”
All of these efforts help to ensure that Penn State’s annual security report (ASR), which is another responsibility of Gates’, is accurate and complete.
Paying Attention to Details Is Key
So what should your institution look for if it has not yet hired a designated Clery compliance coordinator or manager? The ability to collaborate, obviously, is key. Being detail-oriented is also important.
“Someone who is going to be highly successful in Clery compliance is going to need a high level of detail,” says Gates. “Make sure you go through all of the steps to collect all of the crime data and that you are classifying it in the correct geographical locations.”
Robin Hattersley Gray is editor of Campus Safety. She can be reached at firstname.lastname@example.org or 424-738-0211.
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