New policy, tracking system aids Clery Act compliance

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The University of Michigan has developed a new robust process to identify, notify, train and track employees who have responsibility under federal regulations to report certain crimes to the university.

As required under the Jeanne Clery Disclosure of Campus Security Policy and Campus Crimes Act employees identified as campus security authorities — or CSAs — are required to report information about crimes to the university. The Clery Act requires colleges and universities that participate in federal financial aid programs to maintain and disclose crime statistics and security information to the public.

The new U-M policy — Standard Practice Guide 601.91, Clery Act Compliance — outlines the expectations of the U-M Division of Public Safety and Security and CSAs under the Clery Act. It applies to the Ann Arbor, Dearborn and Flint campuses.

“The new policy increases awareness of the important role DPSS and CSAs have in maintaining campus safety and security,” said Eddie Washington, executive director of DPSS. “While employees identified as campus security authorities have an obligation to share information with campus police under the Clery Act, all members of the U-M community are encouraged to report any information about crime.”

DPSS shares crime statistics publicly in an annual security and fire safety report each October. The types of crimes covered include sexual assault, domestic and dating violence, stalking, theft and aggravated assault.

As noted under the policy, CSAs are required to complete annual training to help them understand their role and how to report information on crime to the university. The training is available through My LINC, and must be completed by Sept. 14 and renewed annually. DPSS has sent a message to all identified CSAs on the Ann Arbor campus informing them of their obligation to complete the training.

The university’s Clery compliance manager, Erik Mattila, will identify employees who have not completed CSA training and will work with the appropriate dean, director or department head to ensure compliance.

Non-compliance with training requirements will be reported to the provost, executive vice president and chief financial officer, and executive president for medical affairs for added accountability.

CSAs include:

  • All U-M Police Department officers and DPSS personnel.
  • Other individuals who have responsibility for campus security, but who do not work for DPSS or the U-M Police Department (including contracted security providers).
  • Officials who have significant responsibility for student and campus activities outside of the classroom, such as all deans, department chairs, directors, coaches, advisers to sponsored student organizations, resident advisers and anyone involved with children on campus. Faculty with no other leadership obligations generally are not CSAs.

CSAs differ from individuals with reporting obligations — known as IROs — who also have a responsibility under the U-M Sexual and Gender-Based Misconduct Policy to report information about certain crimes to the university.

IROs are required to share information with the Equity, Civil Rights and Title IX Office about alleged prohibited conduct under U-M policies, and include university administrators and supervisors and employees in certain designated positions and units or departments.

IROs include all staff members — excluding clerical, custodial, maintenance and dining — in Student Life, Athletics, ECRT and DPSS. They also include all faculty and staff serving as identified advisers to sponsored student organizations, and any faculty or staff who accompany students on university-related travel abroad.

The policy was developed with input from the Clery Compliance Workgroup, including DPSS, the Office of the General Counsel and national experts on Clery Act compliance.

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