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On Campus Podcast – Clery Act Training

Season 1 – Episode 22: Clery Act Training

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act or Clery Act is a federal law signed in 1990 that requires institutions of higher education to disclose information regarding campus security. The Clery Act, which amended the Higher Education Act of 1965, is viewed as a consumer protection law, which seeks to provide transparency around crime, policy, and statistics on campus. The Clery Act also requires that institutions of higher education that receive federal funding report crimes that occur on or near campus and implement school safety policies. Training is a central component of Clery Act compliance for the majority of institutions across the United States, specifically for those who have a reporting responsibility under the law. CITI Program’s Clery Act Training course is available to meet institutional compliance needs.


Episode Transcript

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Darren Gaddis: From CITI Program, I’m Darren Gaddis, and this is On Campus. Today, what are the institutional training requirements for the Clery Act, how to facilitate Clery Act training, and the benefits of Clery Act training at an institution. I spoke with Amber Grove, director of Title IX and Clery Compliance at the University of North Carolina Wilmington.

As a reminder, this podcast is for educational purposes only. It is not intended to provide legal advice or guidance. You should consult with your organization’s attorneys if you have questions or concerns about relevant laws and regulations discussed in this podcast. Additionally, the views expressed in this podcast are solely those of their presenter.

Hi, Amber. Thank you for joining me today.

Amber Grove: Thanks so much for having me, Darren.

Darren Gaddis: To get us started today, what is the Clery Act?

Amber Grove: The Clery Act, at its core, is really a consumer protection law based in the higher education sector. In the late ’80s, a student named in Jeanne Clery was sexually assaulted and murdered in her residence hall room at an institution in Pennsylvania. After that happened, her parents started doing some research and found that there was a high level of crime around the area of campus that they had no idea about before Jeanne had committed to, and ultimately went to, that school.

As a result, they started with lobbying the Pennsylvania legislature for increased transparency by higher education institutions about what types of serious crime offenses occur on their campuses. Pennsylvania ultimately passed some state legislation, and then in 1990, the Clerys were successful in having overarching federal legislation passed. Institutions of higher education, as a result, are required to publicize annual security reports. We are required to maintain, and provide to the public upon request, police logs as well as fire logs if we have residence halls on campus. Included in those reports is different emergency information as well, so that way folks can be adequately prepared should the worst happen on campus.

That act has been amended a few times over the years, but has largely remained pretty stable and provided a good foundation for students, faculty and staff, as well as prospective students, faculty and staff, to be able to access the safety information for their campuses and make personal decisions about what’s best for them.

One of the other pieces that is probably most notable and that most people think of when they think of the Clery Act are things like emergency notifications and timely warnings. That really gives individuals real time information when there are pressing situations that require really quick action. We’ve got these longer term, more stable documents, but also short-term emergency response components that really are intended to make sure our students, faculty and staff are on campuses that are as safe as we can make them.

Darren Gaddis: Amber, with all of this information in mind, what are the institutional training requirements for the Clery Act?

Amber Grove: There are a couple of components of training that Clery focuses on. One component that is required is that, as institutions of higher ed, we provide training for all of our current, as well as incoming. Faculty, staff and students on what are referred to as the Violence Against Women Act crimes, so sexual assault, dating violence, domestic violence and stalking. That includes the policies and procedures we have around those issue areas, but also ways to reduce risk and intervene on behalf of another person should they be experiencing some of those issues.

Aside from the VAWA-related training for our campus constituents, the Clery ACT also requires that we train investigators, adjudicators or people that are involved in our sexual misconduct processes to make sure that they are fair and unbiased, and also really well versed in those specific subject areas.

Another piece of training that the Clear Act is not necessarily explicit on, but we’ve seen this in most resolution agreements related to Clery audits, is training of our campus security authorities. We often hear about mandatory reporters of sexual misconduct and sometimes campus security authorities gets lost in the shuffle, but our campus security authorities are really important, in that they provide a good chunk of the Clery crimes that we track and publicize in our crime logs and our annual security reports.

Really, when we look at the resolution agreements, the training that they are required to undergo is to have a basic understanding of the Clery Act and what their obligations are to report crimes and how they do that on their particular campus. With Clery reporting for campus security authorities, really it’s good for them to have a general understanding of the geography of their campus, what types of crimes are reportable, and again, how they can go ahead and make sure to report that information in a timely fashion so that not only can we count the crime stats, but analyze the situations for our timely warning and emergency notification processes.

Darren Gaddis: Why is Clery Act training important to the wider campus community?

Amber Grove: I’ll break that down into the two categories again. First, when we look at the VAWA training, the awareness training for our faculty, staff and students, I think this is an area that otherwise does not get a lot of focus elsewhere. It’s an important topic area that heavily impacts our college campuses. Training our students, faculty and staff to know, first of all, what resources and support are available on campus if they experience something is really helpful. You don’t want to be in a moment of crisis and then have to start finding or digging up that information. Being able to associate a face to the policy and a have an awareness where the website is before you even need it I think is really critical and important. I also think it’s just important that we talk about these topic areas, destigmatize them, so that folks can feel safe reporting if something were to happen.

The other piece of that training, I mentioned the bystander intervention and risk reduction components of the VAWA training, the other hope is that potentially by providing this training to the wide swath of campus, we can actually prevent these types of incidents from happening in the first place, which ultimately is really the goal. I think every Title IX practitioner and the like would love to be out of a job, because that means we were successfully able to adequately train our campus communities and eradicate sexual misconduct.

On the flip side, making sure that our campus security authorities are really adequately trained is important because we have so many campus security authorities who have regular contact with our students, who are taking them on things like athletic trips and the like. Because we have a wide range of people doing those types of activities, there is a wide opportunity for potential incidents to happen while those trips and things occur. It’s really important that those individuals who are on the ground in the moment know how to funnel that information to the right source.

Aside from the idea about making sure we just are adequately tracking the stats and that they’re getting the information in, it’s really important for our timely warnings and emergency notifications. When we look at cases like Virginia Tech and others, some of the criticism that has been levied, whether that’s in the media or in resolution agreements, is about how quickly those types of notifications are made to college campus communities. We’re not able to make the notification quickly if we don’t get the information quickly. Aside from just general knowledge about where they should report, the other piece is that having CSAs really understand the importance of their role, particularly for emergency response, is really critical to making sure we are really truly providing that consumer protection that is at the center of the origins of the Clery Act.

Darren Gaddis: Amber, that’s a ton of information. How do you go about facilitating Clery Act training at an institution?

Amber Grove: There are a number of ways that we can facilitate training. One of the benefits of COVID is that it has forced us to be creative about how we do outreach and training, let alone how we connect with students in the classroom space, and I think we can take a lot of lessons from that. There are a number of things that you can do, and I think a scaffolded approach is really a smart thing to do.

First and foremost, I think it’s always really helpful to make sure that we are notifying our campus community of our VAWA policies, procedures and resources. I think we use the same structure for our CSAs, remind them of their obligations as a CSA, connect them with the policies and procedures related to that, and where their reporting form is. Once you’ve laid that foundation and have something for them in writing that they can come back to, via email I think is always a great place to start, following it up with either in-person or online modules is always helpful.\

The one thing I would say about online modules is that you want to make sure that it’s not one that you just can simply click through without really engaging with. Is there a quiz that’s affiliated with that or some other form of processing that really helps the participant process, understand and test their knowledge and retention of what they’ve just engaged in training on. From the CSA perspective, this sort of knowledge check could potentially be helpful for tracking purposes, and also to show, if you were to get audited, really what learning objectives are being met, for example. If you’re going to do online training modules, I think it’s always helpful to follow up with opportunities for in-person Q&A or town halls or some other in-person component to make sure that there’s a reiteration of what the training entails, but an opportunity to ask questions as well.

I mentioned that I believe in a scaffolded approach, and I do. I think that these are issue areas that are enormously important, and because our day-to-day lives can be so busy, some of this information could be gathered and then shelved. I think it’s really important to make sure that there is some capacity for reminding individuals about their obligations or the training that they’ve participated in, perhaps sending something once a month with a little tip in a newsletter could be one way to just make sure it stays fresh, but really finding ways to keep that messaging and obligation and information at the forefront of folks’ mind is the last piece that I think is really important to incorporate in a training plan for our CSAs, but also for our campus communities on the VAWA crime.

Darren Gaddis: With all of this information in mind, what else should we know about Clery Act training?

Amber Grove: That’s a great question. I think training for the Clery Act can be really simple or really complicated. I think it’s really what you make of it and who your audience is. We often don’t have a lot of time to maybe tailor or set up a really scaffolded and repetitive training approach. I think sometimes we’re also afraid to impinge on people’s time. I think being really strategic about the training and how long it is and who it’s targeted towards is important.

Our university police departments are going to have much different interaction with some of these Clery crimes, the higher level incidents, than our desk attendance maybe in our campus recreation centers, and so the training really maybe shouldn’t look the same for both of those groups. How do we tailor that? Is there a baseline module that gives us the basic information and then we have a more targeted longer training for folks that are more in the weeds and writing the longer reports?

Really being thoughtful about what we do for Clery training and who our audience is important, and frankly, that’s probably true for any type of training that we’re providing, thinking about audience and tailoring accordingly. That way folks really stay engaged and are not being over inundated with information that they don’t need and trying to keep it clean and not confusing.

Darren Gaddis: Amber, as always, thank you for joining me today.

Amber Grove: Thank you so much for having me, Darren. I really appreciate it.

Darren Gaddis: Be sure to follow, like and subscribe to On Campus with CITI Program to stay in the know. I also invite you to review our content offerings regularly, as we are continually adding new courses and webinars that may be of interest to you. All of our content is available to you anytime through organizational and individual subscriptions. You may also be interested in CITI Programs’ Clery Act Training Course. Please visit the CITI Programs website to learn more about all of our offerings.


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Meet the Guest

Amber Grove, Esq – University of North Carolina Wilmington

Amber Grove is an adjunct faculty member and the Director of Title IX and Clery Compliance at the University of North Carolina Wilmington and has served in that role since January 2016. She is a licensed attorney in North Carolina and Pennsylvania.

Meet the Host

Team Member darren gaddis

Darren Gaddis, Host, On Campus Podcast – CITI Program

He is the host of the CITI Program’s higher education podcast. Mr. Gaddis received his BA from University of North Florida, MA from The George Washington University, and is currently a doctoral student at Florida State University.