Post on 06-May-2015
Building and Facilitating a Comprehensive Clery
Act Compliance Program Stephen Shelow
Gabriel GatesSteven Healy
Follow us on Twitter @margolishealy
www.slideshare.net/margolishealy
Introduction
Who we are
The University & System
Division of Police & Public Safety
If You have a Problem…
…you have a Clery problem
High profile incidents
Congressional intent
Student activism
The Price of Non-Compliance
It’s not just about fines
An ED review will significantly affect your institution
In 2011 alone, ED issued 2x the number of FPRDs issued the previous two years and five times the number of reports issued between 2006 - 2008
Where We Were
Prior to 2011, our compliance approach was…
2011, everything changed Major Crisis Dept. of ED at our door step We needed assistance
Retained Margolis Healy
Where We Were
Initial recommendations included creating a Clery Compliance coordinator Selling concept to University Developed job description;
conducted national search Gabe Gates selected
Where We Are
Focused program & approach
Consistency – system wide
High level support for approach
A Holistic Approach to Compliance
Identifying our Campus Security Authorities (CSAs) across a 23 campus system by job function. (HR Training/Definition Interpretation)
Notifying all CSAs of their designation and responsibilities
Revising procedures for collecting crime data CSAs, Campus Law Enforcement, Local Law
Enforcement, Student Conduct, etc.)
Developing Relationships
Margolis Healy & Associates (MHA) Ongoing partnership with MHA
Clery Center for Security on Campus (CCSOC) Partnership with CCSOC to develop a
ground breaking “train the trainer” course
Liaising with Congressional delegation
Educating the Campus Community
A Two-Staged Curriculum:
1. Each Campus Security Authority receives initial classroom training Clery Act requirements and University
reporting procedures.
To date, roughly 200 trainings conducted.
2.All Campus Security Authorities are required to complete an annual online refresher training beginning in 2013.
3. Identified approximately 3,000 employees to receive training.
Increasing Awareness
Conduct “information sessions” to engage campus
community on Clery Act requirements, practices,
and future endeavors.
Variety of audiences, including executive and
academic leadership from University Park as well
as campuses, Faculty Senate governance, and
Intercollegiate Athletics.
University has devoted a renewed effort to
encourage the reporting of crimes. “It is not only what we do, but also what we do not do, for which we
are accountable.”Moliere
Standardizing Procedures
Forms, templates, and detailed guidance to everyone involved with reporting crime statistics: Standardized Campus Security Authority Incident Report
form Comprehensive crime data reporting procedure for
individual campus police/security agencies to report statistics
Standard request for information to all local law enforcement agencies
Clery Mapping for each of our campuses Timely Warning Decision Matrix Testing emergency response and evacuation procedures
Ensuring Accountability
Developed new Administrative policy describing
University’s compliance strategy and expectations (AD 74).
Policy provides protection from retaliation for employees
who report crimes.
Established audit trail to ensure complete and accurate
crime reporting
Campuses are required to conduct annual self audit.
Compliance Coordinator will conduct a comprehensive
audit of each campus every three years (minimum).
Where We’re Going
Response to ED Program Review Report
Newly Established VAWA Reauthorization (SaVE Act) Implementation Team
Developing a Compliance Tracking System
Implemented a “Survival Skills for New Supervisors” program
Working with Legislators to enhance laws like the Clery Act
Possible implementation of standard RMS/CAD system across Commonwealth Campus system
Lessons Learned
Over reporting is as “bad” as under reporting
It isn’t always easy getting folks to the training
Although most were eager
A program review is eye opening
Lessons Learned
Compliance requires full time professional oversight
A good faith effort is not enough
When dealing with Athletics, need buy-in from the highest levels
Records Retention can be a pitfall
Lessons Learned
Compliance is an institutional responsibility
Not an issue of “if,” but when
Acknowledge and understand overlap with Title IX More so with Campus SaVE Act
Need to be proactive with self or peer audit
Questions