All campus units contribute to Clery Act compliance.
The University of Illinois Urbana-Champaign relies on Clery Liaisons from each department to accomplish a few things that we need to comply with the Clery Act. Clery liaisons should report these items as changes occur throughout the year:
- Identify employees who may be Campus Security Authorities
- Identify buildings and property outside the Urbana-Champaign campus that the department uses frequently for teaching or student activities
- Reporting students’ university-sponsored overnight trips away from campus.
Understanding your responsibilities
Understanding the Clery Act
What is the Clery Act, and what is a Clery liaison?
“Clery” refers to the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act which is a federal mandate requiring all institutions of higher education that participate in the federal student financial aid program to disclose information about crime on their campuses and in the surrounding communities.
There is a difference between a Clery liaison and a Campus Security Authority (CSA). A Clery liaison is a role mandated by campus policy to report required information for their units and assist the university with compliance. A CSA is a person who is required by the federal law to report certain crimes to University Police. The video you watched above details the responsibilities of a CSA, not a Clery liaison — but it is nonetheless important to understand the responsibilities of a CSA so you can better understand your responsibilities as a Clery liaison for your department.
Why was the Clery Act implemented?
Jeanne Clery was tragically raped and murdered in her dorm room at Lehigh University in 1986. The law enacted in her memory is intended to ensure that students and others are informed about violent campus crimes so they can make informed decisions. The Clery Act requires universities to report crime statistics to current and prospective students and employees.
Clery Act requirements
The requirements are to:
- Collect, classify, and count reports and statistics related to crime
- Issue timely warnings and campus alerts for Clery crimes that represent an ongoing threat to the safety of students or employees
- Publish an Annual Security and Fire Safety Report and distribute to all current students and employees
- Submit crime statistics to the U.S. Department of Education
- Maintain daily crime and fire logs
- Disclose missing student notification procedures
- Disclose fire safety information related to on-campus student housing
It is important for Clery liaisons to understand the Clery Act compliance procedures at the University of Illinois Urbana-Champaign.
Identifying department CSAs
Who is a CSA?
The law defines four categories of CSAs:
- University Police Department sworn personnel and department administrators
- Non-police people of offices responsible for campus security. These CSAs have security presence or access control authority on university property. Examples:
- security guards
- student patrol officers
- security staff at athletic events
- student ID checkers for Campus Recreation (Facility Managers)
- Officials with significant responsibility for student and campus activities. To help determine these people, consider their job function that involve relationships with students. An official is defined as any person who has the authority and the duty to take action or respond to particular issues on behalf of the University. Examples:
- Student Affairs Professionals
- Student Housing staff (R.A.s, R.D.s, Area Coordinators)
- Athletic Director/Assistant Directors/Coaches (including part-time employees and graduate assistants)
- Student Activities Coordinators
- Title IX Coordinator
- Student Judicial Officers
- Faculty/Staff advisors to student organizations
- Director of Health Center/Admin Nurses
- Victim Advocates or others who are responsible for providing victims with advocacy services
- Faculty/Staff who lead overnight University sponsored student travel
- Any individual or organization specified in an institution’s statement of campus security policy as an individual or organization to which students and employees should report criminal offenses.
The University of Illinois identifies CSAs, and the Title IX and Disability Coordinator as someone else you can report crimes to. They are already included as a CSAs.
Who is not a CSA?
Anyone who does not fall into the above categories is not a CSA. Examples:
- Administrative and clerical staff members who are NOT responsible for students
- A professional staff member who supervises student employees but does not fall into the any of the above categories is NOT a CSA.
- Individual faculty with NO student activity duties outside the classroom
- Doctors at McKinley Health Center
- Counselors in the Counseling Center who ONLY provide care to individual students
Updating your department’s CSA list
You will be asked to review your department’s CSA list twice per year. Typically, the Clery liaison will receive an email in February and September prompting you to review the list.
You can and should add CSAs any time throughout the year. You can complete this form to inform University Police of a CSA in your department.
If a CSA leaves your unit, you do not have to wait until February or September to update the list. Send an email to dps-clery@Illinois.edu and their name will be removed from the list (with the date of separation).
Notifying CSAs of their status
Once you enter someone’s name as a CSA, the Compliance Coordinator will notify them of their status and responsibilities via email. This email will have the link to the required training. The online training takes approximately 30-35 minutes to complete. There is no set time frame for the training to be completed, but we prefer it to be completed within the first two weeks of receiving the email. Reminders will be sent to the CSA until training is complete. After two reminders have been sent, you as the Clery Liaison will be notified in order to help that CSA complete the training.
Reporting non-campus property
What is non-campus property?
Non-campus Property is defined as, “Any building or property owned or controlled by a student organization that is officially recognized by the institution; or Any building or property owned or controlled by an institution that is used in direct support of, or in relation to, the institution’s educational purposes, is frequently used by students, and is not within the same reasonably contiguous geographic area of the institution.”
How to report non-campus property
Clery liaisons should report any non-campus property owned or controlled by their unit using this form.
I report all of my property used through Real Estate and the Contracts Office. Do I still need to report it?
No. University Police work with Facilities and Services, the Real Estate Office, Certified Housing, and Contracts Office to gather information on University owned and controlled properties on an annual basis. If you already have a lease or agreement in place, this location will be captured by the above entities.
Reporting study abroad program locations
If the university sends students to study abroad at an institution we do not own or control, then we do not have to disclose statistics for crimes that occur in those facilities. If the University rents or leases space for our students at these institutions, then these facilities must be reported.
This form is used for a semester or year-long program where we control property. Anything shorter would be considered “travel.”
If the university has a contract with a third-party vendor acting on behalf of the University to arrange housing, these locations specific to our students must be reported.
Typically, host family housing is not included unless there is a written agreement giving the university significant control over a specified area of the home.
Reporting university-sponsored student travel
What is the criteria used to determine when a trip must be reported?
University-sponsored travel means that the university makes the travel arrangements (i.e. has the agreement with the hotel). If a student is making their own arrangements and chooses their own hotel/lodging, then this travel would not count.
Additionally, the duration of travel must be overnight or longer (day trips, or non-overnight travel do not need to be reported).
Also note that this is student travel and not faculty/staff. Graduate student travel must be reported.
How to report university-sponsored travel
Clery liaisons should report any university-sponsored travel using this form.
What if the student is paying for the travel and just getting reimbursed by the department?
The question of who makes the arrangements weighs more heavily in this decision. If the student chooses their own hotel and makes the arrangements themselves, then this travel would not be reportable.
If the unit makes the arrangements and has a contract, written agreement or reservation with the lodging, then this travel would be reportable. For example, when a unit uses their T-card to arrange a hotel for a grad student, this is a reportable location.
Reimbursements made after-the-fact are not reportable.
What we do with the information
At the end of each calendar year, we compile the list of locations where our students traveled, and then identify the law enforcement jurisdiction that has authority over each location. We are required to send this law enforcement agency a letter requesting Clery-reportable crime statistics for this specific location, for the time period that our students were there, and then include these stats in our annual disclosure.
Example: Students stayed at 1234 S. Smith Road, Atlanta, GA, for 5 nights. This is a reportable trip sponsored by the university. We send a letter to Atlanta Police Department asking for the number of Clery crimes at this specific location for the time period our students were staying there. If they report a robbery occurred here during that time frame, we add one robbery to our non-campus statistics.
What to do if you have nothing to report
Not all campus units will have information that needs to be reported or anyone who fits the definition of a CSA. Every campus unit does, however, need to identify a Clery liaison who we can contact in the event that the law or procedures change. We will reach out to you regularly to keep you informed on the changing requirements of the Clery Act so that you can keep up with reporting accurate information from your unit.