Overview of Clery Compliance Audits, Assessments, and Training
Compliance with the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (a.k.a. the Clery Act) is an institutional responsibility. The nuances in the statutes, regulations, and sub-regulatory guidance make compliance with this law more complex than may meet the eye. D. Stafford & Associates offers a variety of compliance assessments as well as Clery Act training programs.
The compliance audits, assessments, and training classes are led by Dolores Stafford, President & CEO, who has been complying with the Clery Act since its inception at the federal level in 1990 as well as complying with its precursor in Pennsylvania, “Act 73,” for which Chief Stafford served as the Act 73 Compliance Officer for Bucknell University when the law was first passed on the state level in Pennsylvania. Chief Stafford has been providing these services as a consultant in the law enforcement and security industry since 1997.
As nationally-recognized experts in the Clery Act, Stafford and her team have assisted many institutions in coming into and maintaining their compliance with federal law by providing various services, all of which can be provided virtually upon request of an institution (which allows for a more flexible schedule and travel cost savings). These services include the following:
Independent Audits of Clery Act Compliance
D. Stafford & Associates has significant expertise and experience in conducting independent reviews/audits of Clery Act compliance for campuses across the country. DSA has conducted more than 750 reviews/audits of the process and methodology for Clery Act compliance at client institutions.
Institutions can choose from any combination of the following four parts, although most institutions opt to complete a full review (which includes all four parts listed below).
- An off-site review of the institution’s Annual Security and Fire Safety Report.
- A review of the institution’s methodology and process for complying with the Clery Act (including the HEOA safety and security provisions and VAWA requirements). Using a proprietary approach, DSA breaks the Clery Act into approximately 20 areas and evaluates existing compliance efforts in each area (typically for the Main Campus of an institution). Topics addressed include (but are not limited to) Clery Geography, Campus Security Authorities, ongoing disclosures, provision of required documents/information to current/prospective students and employees, etc.
- A review of one calendar year of campus police/public safety records to ensure that reportable incidents are being collected, classified, counted, and disclosed correctly by that unit in the institution’s crime statistics. This part includes a review of crime statistics reported to the campus by the local police agency, the campus security authorities (excluding records originating from the housing/residence life unit and the student conduct unit, which is addressed in Part 4), and the Title IX Coordinator to determine if the institution has a system that allows them to accurately capture the total number of crimes that were reported to those entities.
- A review of the relevant process and systems for capturing referral statistics within the housing/residence life unit (if applicable) and the student conduct unit. The review will also involve a spot-check of other Clery-reportable crimes contained in housing/residence life and/or student conduct records to determine if Clery crimes being reported to these entities are being included in the institution’s annual statistical disclosure.
Throughout the review, DSA provides hands-on training and assistance in establishing a model program for the institution to follow when complying with the Clery Act. Parts 2-4 will result in a detailed written report being provided to the institution to outline areas of concern that were identified and provide guidance, suggestions, and specific recommendations to enhance the compliance efforts of the institution. (Part 1 results in a separate report, as described above).
DSA has completed reviews and audits at colleges and universities of various sizes and complexity, including 2-year and 4-year, public and private, urban and rural institutions. DSA has conducted similar work with numerous college and university systems to examine compliance from both an institutional and systemic level.
Off-Site Review of the Institution’s Published Annual Security and Fire Safety Report(s)
D. Stafford & Associates has significant experience in conducting off-site assessments of annual security and fire safety reports, including a review of all policies and procedures that are required to be published as part of the institution’s compliance document. The review will identify missing or inadequate disclosures and will result in a written report that outlines any areas of concern or suggestions for improvement as well as a track-changed version of the institution’s Annual Security and Fire Safety Report.
DSA has conducted such reviews for more than 575 campuses across the country.
Focused Reviews of Clery Compliance
In addition to providing independent audits of an institution’s compliance with the Clery Act, DSA can conduct focused reviews of key areas of Clery Act compliance. By way of illustration and not limitation, institutions can engage DSA to:
- conduct in-person tours of all campuses of the institution (Main Campus and Separate Campuses) to develop Clery Maps for each campus;
- review policies, procedures, and practices related to the assessment, formulation, and distribution of Timely Warning Notices (including a review of incident/police reports to determine if warnings should have been issued as well as a review of the content and timing of notices that were issued);
- examine the institution’s process for identifying, notifying, training, and collecting crime reports from the institution’s Campus Security Authorities;
- review the process of compiling, classifying, counting, reconciling, and disclosing crime and/or fire statistics.
DSA’s unmatched expertise allows us to tailor our services to your institution’s needs.
Part-Time Clery Compliance Officer
D. Stafford & Associates can assign an associate to serve as a part-time Clery Compliance Consultant (i.e., a part-time Clery Compliance Officer) for your institution to provide short-term or long-term assistance in managing the institution’s Clery compliance program. The standard agreement is an annual contract, with options to renew, and the work is generally completed virtually, with periodic travel to the institution as an option, if deemed necessary by DSA and the institution.
The part-time Clery Compliance Consultant is a Subject Matter Expert who is supervised by other subject matter experts including the Vice President and President of DSA and by the appropriate team member from your institution. The part-time Clery Compliance Consultant position is designed to provide continuity and expertise over an extended duration to complete the duties necessary to get the institution into and maintain compliance and to meet the needs of institutions who may not have an existing Clery Compliance Officer position.
This service is primarily* designed to support institutions that have:
- identified the need, but not the funding or talent pool, to hire a dedicated Clery Compliance Officer;
- assigned the coordination of Clery compliance to someone who is overburdened with other duties that consistently divert attention away from coordinating compliance;
- relegated the responsibility for coordinating Clery compliance (by design or default) to someone who lacks the inclination, training, expertise, and/or time to manage Clery compliance effectively at the institution; and/or
- been unable to fill an existing Clery Compliance Officer position, or is a few years out from establishing such a role.
*Institutions with an existing Clery Compliance Officer may also benefit from adding a Part-Time Clery Compliance Consultant to their team to support the existing CCO on a short- or long-term basis.
This model of maintaining Clery Compliance would:
- Provide the institution with the peace of mind knowing that a qualified professional is at the helm of your Clery Act compliance efforts;
- Bypass the challenges and costs associated with recruiting, hiring, retaining, training, and supervising a benefits-eligible employee;
- Ensure continuity of leadership and focused attention on relevant compliance activities;
- Help your institution respond to evolving guidance and regulatory changes that affect Clery compliance; and
- Enhance the institution’s administrative capability with the unmatched practical expertise of D. Stafford & Associates and market-leading Clery compliance software.
Contact Dolores Stafford at firstname.lastname@example.org or call 202-438-5929 to obtain a scope of work and to discuss how a part-time Clery Compliance Consultant can best meet your institution’s needs.
 This service is distinctly different from our existing Interim Clery Compliance Officer/Coordinator Placement Service, which allows a school to contract with DSA to step in an existing CCO who is out of the office or leaves the institution for a short period of time (3-6 months) to serve as the FT or PT CCO until the CCO returns or institution is able to hire a permanent CCO.
Clery Implementation Services
D. Stafford & Associates can help your institution develop and implement policies, procedures, and practices that will demonstrate your institution’s administrative capability and facilitate the institution’s compliance with the Clery Act as required by its Program Participation Agreement with the U.S. Department of Education. DSA will begin by reviewing existing policies and procedures that have been reduced to writing and interview key officials involved in carrying out those policies and procedures. We will then develop and/or enhance those policies and procedures and ensure the presence of strong internal controls to facilitate compliance.
Clery Vulnerability Assessment: A 12-point Inspection
Have you considered whether information that is publicly-available, for example on your institution’s website, is demonstrating compliance with the Clery Act, or providing evidence to the contrary? Would your institution benefit from a low-cost, independent assessment of publicly-available consumer information? We have developed a methodology for conducting an off-site review of 12 key compliance areas that, where deficient, tend to suggest more systemic compliance failures. This type of information is low-hanging fruit for a Department of Education Media Review or Audit. If you can’t afford a complete independent audit, this type of review would be a great start in having a focused external review of your institution’s Clery compliance. We will employ a proprietary methodology and provide the institution with a report of our findings, identifying any specific shortcomings and recommended actions for enhancing compliance.
Post-Incident Analysis/Simulated Media Review
Has your campus recently experienced a safety or security-related incident that made a blip (or a series of blips) in the campus, local, regional, and/or national news? Are you interested in obtaining an objective evaluation of the institution’s response to the incident from a Clery Act perspective by leading experts in the field? Would you like to participate in a simulation of an off-site media review to test your current capacity for successfully weathering an ED media or complaint-based review? If so, DSA can assist the institution by reviewing the following:
- Copies of the original incident report(s), any available supplements (such as investigative reports) and internal communications/emails related to the event;
- The corresponding Daily Crime Log entry, if an entry was added to the Log as a result of the event;
- Applicable statements of policy, as published in the Annual Security Report, pertaining to Timely Warning Notifications and/or Emergency Notifications (or other statements of policy related to the incident under review) to determine whether the policy statements meet minimum standards and were followed in response to the incident;
- Any internal policies, protocols, or procedures that describe in greater detail how the institution assesses reports of crimes or other emergencies for potential distribution of a Timely Warning Notice and/or an Emergency Notification (to allow us to determine if these documents are consistent with published statements of policy, and whether or not these policies/procedures/protocols were followed, as applicable, in response to the event; and
- Any Timely Warnings, Emergency Notifications or other institutional communication(s) distributed in response to the event
U.S. Department of Education (ED) Audit/Review Assistance
Have you been notified that you are being audited by ED via a general financial aid review or a campus security-focused program review?
D. Stafford & Associates is prepared to conduct a pre-audit review (on-site or off-site, time permitting) to assist you in planning for a scheduled audit to identify areas of weakness that can be rectified prior to the arrival of ED reviewers. DSA can also assist the institution with development of a response to questions and requests that precede the on-site program review. DSA can also assist the institution in preparing its response to the Program Review Report that outlines the Department’s preliminary findings and required actions.
Have you been notified that you are the subject of Media Assessment?
D. Stafford & Associates can assist the institution in reviewing and/or preparing information requested by ED to help put the institution in the strongest position to demonstrate compliance. We can also help identify potential compliance shortfalls from the outset of the review and recommend remedial actions the institution can take to mitigate the violation and prevent its recurrence. Such services can help the institution demonstrate its good-faith efforts to get into and maintain compliance in any deficient areas identified during our review.
We can provide a list of satisfied clients who have used this service prior to responding to a Department of Education media assessment.
Clery Act Training Classes for Individual Institutions, Consortia, or Systems of Higher Education
D. Stafford & Associates provides on-site or virtual training classes for individual institutions of higher education as well as consortia or systems that wish to bring Clery Act training to their employees/members.
DSA has several options for classes that can be held at an individual institution, including standard 1 or 2 day classes, depending on the level of detail requested by the client. If an institution or system is having specific challenges in certain areas of complying with the Clery Act and would like the training to focus on those areas, DSA can customize the training to fit the institution’s needs.
DSA can suggest individuals and offices to invite to attend to ensure that all aspects of the Clery Act (including the VAWA and HEOA amendments) are understood by key administrators who are, or will be, involved in the compliance effort.
We also offer on-site training sessions for Campus Security Authorities and we facilitate round-table discussions with the senior leadership, Clery compliance committees, governing board members, and others regarding the key challenges and issues being faced by campuses across the country. DSA is also able to facilitate a ½ day or full day training on the Drug-Free Schools and Communities Act, which is also being monitored and enforced by the Office of Federal Student Aid (the same Office that monitors and enforces compliance with the Clery Act).
DSA has provided on-site and virtual trainings for more than 160 institutions. D. Stafford also conducts regular national training classes for individuals who need to attend a Clery training class. Click here to learn more about our national Clery Act Compliance training programs or to register an individual to attend one of the training programs.