Ensuring Administrative Capacity to Address Clery Act Compliance: A Campus Example
California State University, Monterey Bay
According to the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act, 20 U.S.C. § 1092(f)), any U.S. postsecondary institution that receives federal funds towards student education must meet a variety of requirements involving statistical disclosures, immediate notification, and safety policy for campus criminal and emergency incidents. Any insufficient handling of compliance from a campus threatens prospective student and employee recruitment, current student and employee retention, and external stakeholder influence and support. Still, these risks to a college or university’s reputation and credibility are symptoms of an academic institution’s inefficiency and are demonstrated in program reviews conducted by the U.S. Department of Education that resulted in civil penalties and negative media attention for numerous campuses.
Contributing factors to this problem may include academic institutions failing to designate a dedicated position to implement and ensure Clery Act compliance, as well as the role of leadership and lack of administrative support. Despite whatever resistance may exist, it is vehemently clear throughout the totality of final program review determination letters that Clery Act compliance is an institutional responsibility. This dependency on inter-departmental collaboration demands commitment, planning, and coordination; thus, the necessity of a Clery Compliance Team. However, team dynamics will differ between campuses as a reflection of the varying nature of higher education and the myriad differences stemming from institutional characteristics.
This presentation will discuss Clery Act compliance programmatically and review the standards of administrative capability as defined in 34 C.F.R. § 668.16 and the definition of noncampus property as outlined in the Handbook for Campus Safety and Security Reporting, 2016 edition. The purpose of this presentation is to connect this discussion to the experience of the California State University, Monterey Bay (CSUMB) Clery Director in developing a high-performance work team to achieve a single programmatic element – identifying its noncampus geography. For 2018, the CSUMB Clery Director worked with nineteen campus departments to identify over 150 noncampus building and properties through a devised assessment and tracking process. This geography included owned and controlled spaces, predominantly stemming from student travel, both international and domestic.
From drawing parallels between federal requirements and the efforts of CSUMB to meet compliance, attendees should be able to:
- Understand the foundational needs for program administration.
- Identify the stages of team development and considerations to productivity.
- Compare their campus resources to that of CSUMB and develop an initial plan for identifying noncampus Clery geography at their institution.