Preparing for Your Annual Clery Act Security Report
This summer, the Department of Education published the latest edition of its Handbook for Campus Safety and Security Reporting, which outlines the updated requirements for Clery Act compliance. The Clery Act requires colleges and universities that accept federal funding to share information about crimes on campus and to implement certain policies to keep students and employees safe.
The Clery Act also requires schools to publish an Annual Security Report (ASR) containing crime stats from the three previous years. This year, schools must distribute their complete Annual Security Report to all current students and employees by October 1.
Clery Act violations can result in fines of up to $35,000 per violation, so it’s essential for colleges to maintain proper reporting and documentation throughout the year. Here are a few things to keep in mind as your institution prepares for the ASR deadline:
Clarify what qualifies as on-campus
The updated Handbook lays out some guidelines for what places are considered as part of a university’s jurisdiction. This includes any places owned or controlled by the school, associated foundations, alumni groups, etc; property within a mile of the campus border; student housing areas; and university-controlled study abroad programs.
As you prepare your Annual Security Report, take stock of all the different places that could be considered “on-campus” to make sure your stats accurately cover all the required areas.
Re-examine policies and procedures for crime prevention, classification and reporting
One significant change in the new Handbook is the update on requirements for reporting incidents of sexual assault. The new guidelines require universities to report all incidents of “rape, fondling, incest and statutory rape,” regardless of consent. University policies also must incorporate practices to prevent and respond to dating violence, domestic violence and stalking incidents, as laid out by the 2013 Violence Against Women Act (VAWA) amendments.
Other new regulations address reporting arrests and referrals and clarify where Clery Act hierarchy does and doesn’t apply. These changes make it even more important to thoroughly train your staff on how to document and accurately classify incidents.
Ensure proper documentation of the process
Proper documentation is the biggest factor of Clery Act compliance. The first step is training your officers and security guards to collect detailed accounts, follow privacy requirements and understand victim’s rights. Using a digital document management system makes it easier for officers to document criminal activity, collaborate with local law enforcement and refer to policies and procedures whenever needed.
A document management system will also keep documents secure and organized for the required retention time. It can help maintain records of the distribution of the Annual Security Report and other notifications of criminal activity, and make it easy to demonstrate how your policies and practices comply with the Clery Act.
Clery Act compliance doesn’t have to be overwhelmingly complex. As your institution prepares this year’s Annual Security Report, remember that it all starts with effective policy management.