Following an independent review requested by the University of Connecticut to identify shortcomings in how UConn was meeting the requirements of a federal law known as the Clery Act, the University has taken significant steps to improve its compliance, according to a presentation delivered Wednesday by Chief of Police Barbara O’Connor.
Speaking to the Board of Trustees, O’Connor explained that, shortly after her arrival in 2012, the University commissioned a review by the D. Stafford & Associates firm. That review resulted in 75 recommendations related to Clery Act compliance in areas ranging from the collection of crime data to the training of employees categorized as “campus security authorities” under the act.
”While Stafford’s review found no deficiencies in campus safety, it identified areas where we were not in compliance with federal reporting and other requirements,” O’Connor said. “We wanted to take the initiative to identify and correct the problems ourselves.”
The Jeanne Clery Disclosure of Campus Security Policy & Crime Statistics Act is a federal law administered by the Department of Education that applies to all colleges and universities that receive Title IV student financial aid funding, which includes nearly all U.S. higher education institutions.
Under the law, schools are required to publish an annual security report, maintain a public crime log, report crime statistics for incidents on campus and certain non-campus areas, issue timely warnings about crimes that could pose a serious threat to students and employees, devise emergency notification and response policies, report fire data, and create policies to address reports of missing students.
The review was the initiative of O’Connor, who came to the University in 2012 from the University of Illinois. An expert on Clery, O’Connor immediately identified compliance with Clery as an area that needed to be reviewed.
“I wanted to bring in an independent reviewer who could go through our process in a systematic, thorough way and give us an opportunity to address these issues ourselves with the benefit of outside expertise,” she said.
O’Connor’s report was delivered to the Board of Trustees as the University waits for the findings of a Department of Education audit of Clery compliance that was conducted in 2011 to review compliance in earlier years. O’Connor expects the audit to find deficiencies previously identified by the Stafford report, including those that are already being addressed.
O’Connor said that it has been the Department of Education’s practice to impose fines when an audit reveals past deficiencies in compliance.
Typically, the Department of Education sends a preliminary report to institutions before making the audit public, but UConn has not yet received that report, and the federal statute does not prescribe a specific timetable for the completion and distribution of Clery audits.
Stafford & Associates spent about two weeks on campus in 2012 conducting research and training University staff. At the time of Stafford’s review, the firm estimated that UConn was at roughly 60 percent to 70 percent in terms of total compliance with the Clery Act.
“There were some errors and omissions … but most of them were caused by a lack of understanding of some of the nuances of this complex law,” Stafford’s staff wrote in their report, which was completed in September 2012.
“If all of the recommendations are implemented, there is no doubt that the University of Connecticut will be a model agency in terms of compliance with the Clery Act,” the Stafford report said.
Among the problems cited in the report were: the absence of a standard operating procedure for notifying the University community about emergencies; the lack of tests or drills of emergency response procedures; and the failure to gather crime statistics from so-called “campus security authorities,” which the report calls “a significant issue of non-compliance.”
Under the Clery Act, “campus security authorities” include everyone from resident assistants to coaches of athletic teams to faculty advisors of student organizations to security guards hired on a contract basis for special events.
Since the report was completed, UConn has taken numerous steps to implement its recommendations, O’Connor said. The University has identified more than 800 people who qualify as campus security authorities and is currently training them on their responsibilities under Clery; more than 400 have completed training so far.
Additionally, the University has revamped its crime alert process, created a procedure for notifying the University about emergencies, developed a timely system for the distribution of reports involving student violations of the law or the University’s Student Conduct Code to the Office of Community Standards, begun regular tests of emergency procedures, and hired a permanent, full-time University employee charged with overseeing Clery compliance, something few other universities have.
“To do this and to do it well, it can’t be an ancillary or part-time duty,” O’Connor said. “Compliance with the Clery Act is something we do full-time.”
