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

2. Follow us onTwitter
@margolishealy
www.slideshare.net/margolishealy

3. Introduction
 Who we are
 The University & System
 Division of Police & Public Safety

4. IfYou have a Problem…
 …you have a Clery problem
 High profile incidents
 Congressional intent
 Student activism

5. 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

6. WhereWeWere
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

7. WhereWeWere
Initial recommendations included
creating a Clery Compliance coordinator
Selling concept to University
Developed job description; conducted
national search
GabeGates selected

8. WhereWe Are
Focused program & approach
Consistency – system wide
High level support for approach

9. A Holistic Approach to Compliance
Identifying our Campus Security Authorities
(CSAs) across a 23 campus system by job
function. (HRTraining/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.)

10. 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

11. Educating the Campus Community
ATwo-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.

12. Increasing Awareness
 Conduct “information sessions” to engage campus community
onClery 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

13. 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
 TimelyWarning Decision Matrix
 Testing emergency response and evacuation procedures

14. EnsuringAccountability
 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).

15. WhereWe’re Going
 Response to ED Program Review Report
 Newly EstablishedVAWA Reauthorization (SaVE Act)
ImplementationTeam
 Developing a ComplianceTracking 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

16. 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

17. 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

18. Lessons Learned
 Compliance is an institutional responsibility
Not an issue of “if,” but when
 Acknowledge and understand overlap withTitle IX
 More so with Campus SaVE Act
 Need to be proactive with self or peer audit

19. Questions