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California State Auditor Report Number : 2015-032

California’s Postsecondary Educational Institutions
More Guidance Is Needed to Increase Compliance With Federal Crime Reporting Requirements

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Appendix A   Appendix B   Appendix C



Appendix A

CRIMES AND VIOLATIONS THAT POSTSECONDARY EDUCATIONAL INSTITUTIONS MUST REPORT UNDER FEDERAL CRIME STATISTICS DISCLOSURE REQUIREMENTS

The federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act and federal regulations require all postsecondary educational institutions that participate in federal student aid under Title IV of the Higher Education Act of 1965 (Title IV) to report statistics for the categories of criminal offenses and violations shown in Table A.13

Table A
Crimes and Violations Reportable Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Crime/Violation Applicable Definition
Aggravated assault Unlawful attack by one person upon another for the purpose of inflicting severe or aggravated bodily injury. This type of assault usually is accompanied by the use of a weapon or by means likely to produce death or great bodily harm. However, it is not necessary that injury result from an aggravated assault when a gun, knife, or other weapon is used that could and probably would result in serious personal injury if the crime were successfully completed.
Arson Any willful or malicious burning or attempt to burn, with or without intent to defraud, a dwelling house, public building, motor vehicle or aircraft, or personal property of another.
Burglary Unlawful entry of a structure to commit a felony or a theft. For reporting purposes this definition includes the following: unlawful entry with intent to commit a larceny or felony, breaking and entering with intent to commit a larceny, housebreaking, safecracking, and all attempts to commit any of the aforementioned.
Motor vehicle theft Theft or attempted theft of a motor vehicle. This includes all cases in which automobiles are taken by persons not having lawful access, even though the vehicles are later abandoned—including joyriding.
Murder and nonnegligent manslaughter Willful (nonnegligent) killing of one human being by another.
Negligent manslaughter The killing of another person through gross negligence.
Robbery Taking or attempting to take anything of value from the care, custody, or control of a person or persons by force or threat of force or violence and/or by putting the victim in fear.
Sex offense, forcible Any sexual act directed against another person, forcibly and/or against that person’s will, or not forcibly or against the person’s will where the victim is incapable of giving consent.
Sex offense, nonforcible Unlawful sexual intercourse not performed by force, such as incest or statutory rape.
Drug abuse violation Violation of laws prohibiting the production, distribution, and/or use of certain controlled substances and the equipment or devices utilized in their preparation and/or use; the unlawful cultivation, manufacture, distribution, sale, purchase, use, possession, transportation, or importation of any controlled drug or narcotic substance; and arrests for violations of state and local laws, specifically those related to the unlawful possession, sale, use, growing, manufacturing, and making of narcotic drugs.
Liquor law violation The violation of state or local laws or ordinances prohibiting the manufacture, sale, purchase, transportation, possession, or use of alcoholic beverages, not including driving under the influence and drunkenness.
Weapon law violation Violation of laws or ordinances prohibiting the manufacture, sale, purchase, transportation, possession, concealment, or use of firearms, cutting instruments, explosives, incendiary devices, or other deadly weapons.
Hate crimes Crimes reported to local police agencies or to a campus security authority that are any of the crimes described previously, other than violations of liquor, drug, or weapons laws; as well as larceny‑theft, simple assault, and intimidation; destruction, damage, or vandalism of property; and any other crimes involving bodily injury that manifest evidence that the victim was intentionally selected because of the victim’s actual or perceived race, gender, religion, sexual orientation, ethnicity, or disability.
Dating violence Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim; and where the existence of such a relationship shall be determined based on a consideration of the following factors: the length of the relationship, the type of relationship, or the frequency of interaction between the persons involved in the relationship.
Domestic violence Felony or misdemeanor crimes of violence committed by a current or former spouse or intimate partner of the victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, by a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant moneys, or by any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction.
Stalking Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for her, his, or others’ safety or to suffer substantial emotional distress.

Sources: Code of Federal Regulations, Title 34, Section 668.46, Appendix A to Subpart D of Part 668, and United States Code, Title 42, Section 13925.


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Appendix B

CRIME STATISTICS IN THE 2014 ANNUAL SECURITY REPORTS OF THE SIX POSTSECONDARY EDUCATIONAL INSTITUTIONS

The federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) and federal regulations require all postsecondary educational institutions (institutions) that participate in federal student aid under Title IV of the Higher Education Act of 1965 (Title IV) to report statistics for the categories of criminal offenses and violations described in Appendix A.14 Tables B.1 through B.6 below summarize the criminal offenses, arrests, and disciplinary actions that the six institutions we visited reported for 2011, 2012, and 2013.

Table B.1
Fresno City College’s Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011 2012 2013
Enrollment 28,230 29,744 30,360
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 1 0 1
Arson 7 1 0
Burglary 33 16 17
Motor vehicle theft 10 15 22
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 1 4 9
Sex offenses, forcible 0 0 0
Sex offenses, nonforcible 0 0 0
Subtotals 52 36 49
Clery Act Arrests
Drug abuse arrests 19 4 15
Liquor law arrests 5 0 4
Weapon law arrests 6 0 3
Subtotals 30 4 22
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 2 0 3
Liquor law disciplinary actions 0 0 3
Weapon law disciplinary actions 0 0 0
Subtotals 2 0 6
Totals 84 40 77

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of February 23, 2015, and enrollment data from the California Community Colleges Chancellor’s Office’s annual 2011–12, 2012–13, and 2013–14 student counts.

Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.


Table B.2
San Francisco State University’s Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011 2012 2013
Enrollment 24,782 30,500 29,905
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 4 0 1
Arson 1 4 1
Burglary 41 42 13
Motor vehicle theft 18 16 26
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 6 3 5
Sex offenses, forcible 4 0 4
Sex offenses, nonforcible 0 0 0
Subtotals 74 65 50
Clery Act Arrests
Drug abuse arrests 45 24 10
Liquor law arrests 28 18 27
Weapon law arrests 5 2 6
Subtotals 78 44 43
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 0 31 9
Liquor law disciplinary actions 235 169 170
Weapon law disciplinary actions 0 0 0
Subtotals 235 200 179
Totals 387 309 272

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of February 23, 2015, and the California State University’s fall 2011, fall 2012, and fall 2013 enrollment data. Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.


Table B.3
Shasta College’s Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011* 2012* 2013*
Enrollment 12,727 12,215 12,465
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 7 9 24
Arson 1 0 0
Burglary 2 12 12
Motor vehicle theft 2 0 1
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 1 0 0
Sex offenses, forcible 6 1 5
Sex offenses, nonforcible 0 0 0
Subtotals 19 22 42
Clery Act Arrests
Drug abuse arrests 1 3 39
Liquor law arrests 0 4 3
Weapon law arrests 0 1 11
Subtotals 1 8 53
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 30 16 11
Liquor law disciplinary actions 15 20 9
Weapon law disciplinary actions 1 5 3
Subtotals 46 41 23
Totals 66 71 118

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of April 14, 2015, and enrollment data from the California Community Colleges Chancellor’s Office’s annual 2011–12, 2012–13, and 2013–14 student counts.

Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.

* Shasta College (Shasta) reported two hate crimes in 2011, two in 2012, and two in 2013. Hate crimes are reported separately by the institution.

Shasta’s director of campus safety stated that Shasta performed a review of the 2013 crime statistics it reported to OPE in October 2014 and corrected some inaccuracies. However, Shasta’s review was not finalized and submitted to OPE until April 2015, which was after our file review; therefore, we did not verify the accuracy of the revised crime statistics.


Table B.4
Stanford University’s Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011* 2012 2013
Enrollment 19,945 18,217 18,136
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 2 12 3
Arson 5 0 0
Burglary 109 113 96
Motor vehicle theft 21 18 19
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 2 1 2
Sex offenses, forcible 12 26 26
Sex offenses, nonforcible 0 0 0
Subtotals 151 170 146
Clery Act Arrests
Drug abuse arrests 20 6 9
Liquor law arrests 40 52 89
Weapon law arrests 2 2 4
Subtotals 62 60 102
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 3 0 0
Liquor law disciplinary actions 1 0 7
Weapon law disciplinary actions 0 0 0
Subtotals 4 0 7
Totals 217 230 255

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of May 13, 2015, and Stanford University’s October 2011, October 2012, and October 2013 enrollment data.

Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.

* Stanford University reported one hate crime in 2011. Hate crimes are reported separately by the institution.


Table B.5
University of California, San Diego’s Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011 2012* 2013
Enrollment 29,324 29,059 30,310
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 6 11 8
Arson 4 0 1
Burglary 31 25 55
Motor vehicle theft 38 24 27
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 0 2 4
Sex offenses, forcible 6 12 20
Sex offenses, nonforcible 0 0 0
Subtotals 85 74 115
Clery Act Arrests
Drug abuse arrests 23 25 46
Liquor law arrests 119 40 67
Weapon law arrests 1 0 7
Subtotals 143 65 120
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 357 588 406
Liquor law disciplinary actions 1,238 1,781 1,707
Weapon law disciplinary actions 5 9 3
Subtotals 1,600 2,378 2,116
Totals 1,828 2,517 2,351

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of February 23, 2015, and the University of California’s fall 2011, fall 2012, and fall 2013 enrollment data.

Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.

* University of California, San Diego, reported one hate crime in 2012. Hate crimes are reported separately by the institution.


Table B.6
University of Redlands’ Reported Crime Statistics Under the Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
Number Reported
2011 2012 2013
Enrollment* 4,769 4,956 5,147
Federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) Criminal Offenses
Aggravated assault 0 2 2
Arson 0 1 0
Burglary 29 10 18
Motor vehicle theft 5 15 8
Murder and nonnegligent manslaughter 0 0 0
Negligent manslaughter 0 0 0
Robbery 0 1 3
Sex offenses, forcible 10 9 3
Sex offenses, nonforcible 0 1 0
Subtotals 44 39 34
Clery Act Arrests
Drug abuse arrests 0 0 0
Liquor law arrests 0 0 0
Weapon law arrests 2 0 2
Subtotals 2 0 2
Clery Act Disciplinary Actions
Drug abuse disciplinary actions 110 130 114
Liquor law disciplinary actions 425 354 315
Weapon law disciplinary actions 4 6 8
Subtotals 539 490 437
Totals 585 529 473

Sources: Crime statistics, which are based on a calendar year, from the U.S. Department of Education’s Office of Postsecondary Education (OPE) Campus Safety and Security Statistics website as of May 13, 2015, and the University of Redlands’ fall 2011, fall 2012, and fall 2013 enrollment data.

Note: The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to, among other things, require postsecondary educational institutions (institutions) to compile statistics for incidents of domestic violence, dating violence, sexual assault, and stalking. However, institutions are not required to submit these statistics to OPE until fall 2015. As a result, certain crimes listed in Appendix A and Table 1 are not included in tables B.1 through B.6.

* Enrollment data is reported on a school year basis, while crime statistics are reported on a calendar year basis. For the purposes of this table, we included the 2011–12 enrollment data for the 2011 crime statistics, the 2012–13 enrollment data for the 2012 crime statistics, and 2013–14 enrollment data for the 2013 crime statistics.


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Appendix C

COMPLIANCE OF THE SIX POSTSECONDARY EDUCATIONAL INSTITUTIONS WITH FEDERAL LAW AND REGULATIONS REGARDING DISCLOSURE OF SECURITY POLICIES

The federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) and federal regulations require all postsecondary educational institutions (institutions) that participate in federal student aid under Title IV of the Higher Education Act of 1965 (Title IV) to prepare annual security reports that disclose certain campus security policies.15 The Violence Against Women Reauthorization Act of 2013 amended the Clery Act to require institutions to include in their annual security reports certain policies, procedures, and programs pertaining to domestic violence, dating violence, sexual assault, and stalking, and the procedures the institutions will follow if such conduct occurs. Federal law and regulations describe 46 specific policies that each institution must disclose in its annual security report. These policies include procedures for students and others to report criminal actions. Table C indicates whether the six institutions we visited fully disclosed each of the required policies in their most recent annual security reports.


 
Table C
Six Postsecondary Educational Institutions’ Compliance With Federal Law and Regulations Regarding Disclosure of Security Policies
Postsecondary educational Institution (Institution)
Description of Policy  Fresno City College San Francisco State University Shasta College Stanford University University of California, San Diego University of Redlands
Policies Concerning Annual Reports and Access to Campus
1 Disclosed its 2011, 2012, and 2013 crime statistics in its annual security report.
2 Policies for making timely warning reports to the campus community regarding the occurrence of crimes.
3 Policies for preparing annual disclosure of crime statistics.
4 A list of the titles of each person or organization to whom students and employees should report criminal offenses, and disclosure of policies and procedures, if any, that allow victims or witnesses to report crimes on a voluntary, confidential basis.
5 A statement of current policies concerning security of and access to campus facilities, including campus residences, and security considerations used in maintenance of campus facilities.
6 A description of procedures, if any, that encourage pastoral counselors and professional counselors, if and when they deem it appropriate, to inform the persons they are counseling of any procedures to report crimes on a voluntary, confidential basis for inclusion in the annual disclosure of crime statistics.
Policies Concerning Campus Law Enforcement and Crime Prevention
7 A statement of current policies concerning campus law enforcement, including the law enforcement authority of campus security personnel; the working relationship of campus security personnel with state and local law enforcement agencies, including whether the institution has agreements with such agencies, such as written memoranda of understanding, for investigation of alleged criminal offenses.
8 Policies that encourage accurate and prompt reporting of all crimes to the campus police and the appropriate law enforcement agencies, when the victim of such crime elects to or is unable to make such a report. Partially Disclosed
9 A description of the type and frequency of programs designed to inform students and employees about campus security procedures and practices and to encourage students and employees to be responsible for their own security and the security of others.
10 A description of programs designed to inform students and employees about prevention of crime.
11 A statement of policy concerning the monitoring and recording through local police agencies of criminal activity at off‑campus student organizations that are recognized by the institution and that are engaged in by students attending the institution, including those student organizations with off‑campus housing.
Policies Concerning Illegal Drugs and Alcohol
12 A statement of policy regarding the possession, use, and sale of alcoholic beverages and enforcement of state underage drinking laws.
13 A statement of policy regarding the possession, use, and sale of illegal drugs and enforcement of federal and state drug laws.
14 A description of programs for drug or alcohol abuse education.
Policies Regarding Campus Sex Offense Programs and Procedures
15 A description of educational programs to promote the awareness of rape, acquaintance rape, domestic violence, dating violence, sexual assault, and stalking. These programs should include primary prevention and awareness programs for all incoming students and new employees, which must include a statement that the institution prohibits the offenses of domestic violence, dating violence, sexual assault, and stalking, including the definition of these crimes; the definition of consent in reference to sexual activity; safe and positive options for bystander intervention; and information on risk reduction to recognize warnings of abusive behavior and avoid potential attacks, and ongoing prevention and awareness campaigns for students and faculty. Partially Disclosed Partially Disclosed Partially Disclosed Partially Disclosed
16 A statement of the procedures an institution will follow once an incident of domestic violence, dating violence, sexual assault, or stalking has been reported, including a statement of the standard of evidence that will be used during any institutional conduct proceeding arising from such a report. Procedures victims should follow if a sex offense, domestic violence, dating violence, sexual assault, or stalking has occurred, including information in writing about the importance of preserving evidence as may be necessary to the proof of criminal domestic violence, dating violence, sexual assault, or stalking, or in obtaining a protection order. Partially Disclosed
17 Options regarding notifying law enforcement and campus authorities, including notification of the victim's options to notify proper law enforcement authorities, including on‑campus and local police; be assisted by campus authorities in notifying law enforcement authorities if the victim so chooses; and decline to notify such authorities.
18 Written notification of student and employees about existing counseling, health, mental health, victim advocacy, legal assistance, and other services available for victims both on campus and in the community.
19 Written notification of victims about options for, and available assistance in, changing academic, living, transportation, and working situations, if requested by the victim and if such accommodations are reasonably available, regardless of whether the victim chooses to report the crime to campus police or law enforcement. Partially Disclosed Partially Disclosed Partially Disclosed
20 A description of the rights of victims and the institution's responsibilities regarding orders of protection; no‑contact orders; restraining orders; or similar lawful orders issued by a criminal, civil, or tribal court. Not Disclosed Partially Disclosed Partially Disclosed
21 A statement advising the campus community where specified law enforcement agency information provided by a state concerning registered sex offenders may be obtained.
Processes the Institution Will Use to Take Disciplinary Action in Cases of an Alleged Sex Offense
22 A statement that the accuser and accused are entitled to the same opportunities to have others present during an institutional disciplinary proceeding, including the opportunity to be accompanied to any related meeting or proceeding by an advisor of their choice.
23 A statement of policies that includes that both the accuser and accused will be simultaneously informed in writing of the outcome of any institutional disciplinary proceeding that arises from an allegation of domestic violence, dating violence, sexual assault, or stalking; the institution's procedures for the accused and the victim to appeal the result of the institutional disciplinary proceeding; any change to the results that occurs prior to the time that such results become final; and when such results become final. Partially Disclosed Partially Disclosed Partially Disclosed
24 A statement of policy of possible sanctions or protective measures that an institution may impose following a final determination of an institutional disciplinary procedure regarding rape, acquaintance rape, domestic violence, dating violence, sexual assault, and stalking. Partially Disclosed
25 A statement of the institution's procedures for institutional disciplinary action in cases of alleged domestic violence, dating violence, sexual assault, or stalking, which shall include a clear statement that such proceedings shall provide a prompt, fair, and impartial investigation and resolution, which will be conducted by officials who receive annual training on the issues related to domestic violence, dating violence, sexual assault, and stalking and how to conduct an investigation and hearing process that protects the safety of victims and promotes accountability. Partially Disclosed Not Disclosed
26 A statement of policy on how an institution will protect the confidentiality of victims, including how publicly available record keeping will be accomplished without the inclusion of identifying information about the victim, to the extent permissible by law.
Policies Regarding Campus Emergency Response and Evacuation Procedures
27 A statement of the policies the institution will use to immediately notify the campus community upon the confirmation of a significant emergency or dangerous situation involving an immediate threat to the health or safety of students or employees occurring on the campus.
28 A description of the process to confirm that there is a significant emergency or dangerous situation involving an immediate threat to the health or safety of students or employees occurring on the campus. Not Disclosed
29 A description of the process the institution will use to determine the appropriate segment or segments of the campus community to receive a notification. Not Disclosed
30 A description of the process the institution will use to determine the content of the notification. Not Disclosed
31 A description of the process the institution will use to initiate the notification system.
32 A list of the titles of the person or persons or organization or organizations responsible for carrying out the actions described above.
33 A statement that the institution will, without delay, and taking into the account the safety of the community, determine the content of the notification and initiate the notification system, unless issuing a notification will, in the professional judgment of responsible authorities, compromise efforts to assist a victim or to contain, respond to, or otherwise mitigate the emergency. Not Disclosed
34 The institution’s procedures for disseminating emergency information to the larger community.
35 A statement advising that tests of response and evacuation procedures may be announced or unannounced. Not Disclosed Partially Disclosed Not Disclosed
36 A statement publicizing its emergency response and evacuation procedures in conjunction with at least one test per calendar year. Partially Disclosed Not Disclosed
37 A statement documenting, for each test, a description of the exercise, the date, time, and whether it was announced or unannounced. Not Disclosed Partially Disclosed Not Disclosed
Processes the Institution Will Use When There Is a Report of a Missing Student
38 A statement indicating the list of titles of the persons or organizations to which students, employees, or other individuals should report that a student has been missing for 24 hours.
39 A statement requiring that any missing student report must be referred immediately to the institution's police or campus security department, or to the local law enforcement agency that has jurisdiction in the area.
40 A statement containing an option for each student to identify a contact person or persons whom the institution shall notify within 24 hours of the determination that the student is missing, if the student has been determined missing by the institutional police, campus security department, or local law enforcement agency.
41 A statement advising students that their contact information will be registered confidentially, that this information will be accessible only to authorized campus officials, and that it may not be disclosed, except to law enforcement personnel in furtherance of a missing person investigation. Partially Disclosed Not Disclosed
42 A statement advising students that if they are under 18 years of age and not emancipated, the institution must notify a custodial parent or guardian within 24 hours of the determination that the student is missing, in addition to notifying any additional contact person designated by the student.
43 A statement advising students that the institution will notify the law enforcement agency within 24 hours of the determination that the student is missing, unless the local law enforcement agency was the entity that made the determination that the student was missing.
44 The procedures that the institution must follow when a student who resides in an on‑campus student housing facility is determined to have been missing for 24 hours, including, if the student has designated a contact person, notifying that contact person within 24 hours that the student is missing.
45 The procedures that the institution must follow when a student who resides in an on‑campus student housing facility is determined to have been missing for 24 hours, including, if the student is under 18 years of age and is not emancipated, notifying the student's custodial parent or guardian and any other designated contact person within 24 hours that the student is missing.
46 The procedures that the institution must follow when a student who resides in an on‑campus student housing facility is determined to have been missing for 24 hours, including, regardless of whether the student has identified a contact or is an emancipated minor, informing the local law enforcement agency that has jurisdiction in the area within 24 hours that the student is missing.
Totals
Partially disclosed 4 7 6 0 1 2
Not disclosed 2 5 1 0 0 4
Total disclosure errors 6 12 7 0 1 6

Sources: United States Code, Title 20, Section 1092(f); Code of Federal Regulations, Title 34, Section 668.46; and information obtained from the institutions.

Note: Table C reflects every component of federal law and regulations regarding disclosure of security policies that we tested at each institution.

✔ = Fully disclosed




Footnotes

13 Title IV, as amended, provides funding to eligible students in the form of Pell grants and other federal student aid, including direct loans. Go back to text

14 Title IV, as amended, provides funding to eligible students in the form of Pell grants and other federal student aid, including direct loans. Go back to text

15 Title IV, as amended, provides funding to eligible students in the form of Pell grants and other federal student aid, including direct loans. Go back to text


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