building & facilitating a comprehensive clery compliance program

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Building and Facilitating a Comprehensive Clery Act Compliance Program Stephen Shelow Gabriel Gates Steven Healy

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Page 1: Building & Facilitating a Comprehensive Clery Compliance Program

Building and Facilitating a Comprehensive Clery

Act Compliance Program Stephen Shelow

Gabriel GatesSteven Healy

Page 2: Building & Facilitating a Comprehensive Clery Compliance Program

Follow us on Twitter @margolishealy

www.slideshare.net/margolishealy

Page 3: Building & Facilitating a Comprehensive Clery Compliance Program

Introduction

Who we are

The University & System

Division of Police & Public Safety

Page 4: Building & Facilitating a Comprehensive Clery Compliance Program

If You have a Problem…

…you have a Clery problem

High profile incidents

Congressional intent

Student activism

Page 5: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 6: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 7: Building & Facilitating a Comprehensive Clery Compliance Program

Where We Were

Initial recommendations included creating a Clery Compliance coordinator Selling concept to University Developed job description;

conducted national search Gabe Gates selected

Page 8: Building & Facilitating a Comprehensive Clery Compliance Program

Where We Are

Focused program & approach

Consistency – system wide

High level support for approach

Page 9: Building & Facilitating a Comprehensive Clery Compliance Program

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.)

Page 10: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 11: Building & Facilitating a Comprehensive Clery Compliance Program

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.

Page 12: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 13: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 14: Building & Facilitating a Comprehensive Clery Compliance Program

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).

Page 15: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 16: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 17: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 18: Building & Facilitating a Comprehensive Clery Compliance Program

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

Page 19: Building & Facilitating a Comprehensive Clery Compliance Program

Questions