2024-032 Clery Act Requirements and Crime Reporting
Six California Colleges and Universities We Visited Struggled to Report Accurate Campus Safety Information
Published: July 30, 2024
Audit Recommendations Disclosure
When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.
Recommendations to Legislature
Recommendation 1
Over the past 21 years, the State Auditor has found noncompliance with federal Clery Act requirements at 41 institutions. If the Legislature desires greater campus focus on and awareness of Clery Act requirements, it could consider requiring all institutions that are subject to the Clery Act to conduct periodic reviews of their compliance with the Clery Act and with state law requirements. The Legislature should require these institutions to post the results of their campus safety reviews publicly and conspicuously on their websites, near the institutions’ annual security reports. At a minimum, the reviews should include the following:
- A review of all campus crimes, to ensure the accuracy and completeness of the institution’s disclosure of all relevant crimes.
- A review of all institutional policies, procedures, and programs, to ensure that they include all required components set forth in the Clery Act and in state law.
- A review of the institution’s annual security reports, to ensure that the institution disclosed all required items in a manner consistent with the institution’s underlying policies, procedures, and programs.
Recommendations to CSU Chico
Recommendation 2
To ensure the accuracy and completeness of campus crime statistics that each institution reports to ED and includes in its annual security report, Chico should establish procedures by January 2025 for compiling the Clery Act statistics. These procedures should include the following:
- Listing all campus departments that maintain crime and incident data and protocols for obtaining data from those departments. Identifying all law enforcement agencies and obtaining all crime and incident data from those agencies.
- Procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics.
Recommendation 7
To ensure that all crimes are recorded in the institution’s daily crime log, Chico should develop procedures by January 2025 for its campus security office or campus police department staff to follow. These procedures should include the list of all institutional departments and law enforcement agencies from which the campus security office or campus police department obtain crime data to include in the institution’s daily crime logs. These procedures should also define who is responsible for obtaining data for inclusion in the daily crime log.
Recommendation 11
To ensure that they fully and adequately disclose all required policies in its annual security reports, Chico should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Recommendation 12
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, Chico should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Recommendation 13
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, Chico should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Recommendation 14
Chico should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Recommendation 15
To ensure that it fully complies with state law and best practices related to campus safety, Chico should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Fully implemented
Date of implementation:
September 2024
Evaluator assessment status:
Fully implemented
60-Day Agency Response
Chico State established a Clery Compliance program manual. Chico State and the City of Chico established an updated Joint Public Safety Agreement (MOU). The California State University Office of the Chancellor issued the Interim Nondiscrimination Policy, which includes updated procedures, rights and options. Chico State established updated training materials that will be provided during Student Orientation, as well as updating information available on their campus website. Chico State’s EODR (TIX) office created a brochure which highlights campus processes and resources.
Public Reasoning Behind Assessment
Chico State demonstrated that it has adopted or updated its policies, procedures, and programs to comply with all the requirements of state law shown in Appendix D of our report.
Recommendations to Imperial Valley College
Recommendation 3
To ensure the accuracy and completeness of campus crime statistics that each institution reports to ED and includes in its annual security report, Imperial Valley should establish procedures by January 2025 for compiling the Clery Act statistics. These procedures should include the following:
- Listing all campus departments that maintain crime and incident data and protocols for obtaining data from those departments. Identifying all law enforcement agencies and obtaining all crime and incident data from those agencies.
- Procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
We are working with PaxBello Consulting Services and with our legal counsel in upgrading all of our campus policies and procedures to ensure compliance with Clery Act, and to improve our communication systems with all stakeholders. This process (updating policies and procedures) requires time as we have to take all updated policies and procedures through our shared governance structure before board approval.
Recommendation 16
To ensure that they fully and adequately disclose all required policies in its annual security reports, Imperial Valley should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Status:
Not fully implemented
Date of implementation:
December 2024
Evaluator assessment status:
Pending
60-Day Agency Response
We have engaged the services of Pax Bello, LLC, to organize and assist with the necessary review and changes outlined in the Audit Report. Furthermore, we have completed a Campus Safety Plan.
Recommendation 17
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, Imperial Valley should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
We are working with PaxBello Consulting Services and with our legal counsel in upgrading all of our campus policies and procedures to ensure compliance with Clery Act, and to improve our communication systems with all stakeholders. This process (updating policies and procedures) requires time as we have to take all updated policies and procedures through our shared governance structure before board approval.
Recommendation 18
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, Imperial Valley should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
We are working with PaxBello Consulting Services and with our legal counsel in upgrading all of our campus policies and procedures to ensure compliance with Clery Act, and to improve our communication systems with all stakeholders. This process (updating policies and procedures) requires time as we have to take all updated policies and procedures through our shared governance structure before board approval.
Recommendation 19
Imperial Valley should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
We are working with PaxBello Consulting Services and with our legal counsel in upgrading all of our campus policies and procedures to ensure compliance with Clery Act, and to improve our communication systems with all stakeholders. This process (updating policies and procedures) requires time as we have to take all updated policies and procedures through our shared governance structure before board approval.
Recommendation 20
To ensure that it fully complies with state law and best practices related to campus safety, Imperial Valley should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
We are working with PaxBello Consulting Services and with our legal counsel in upgrading all of our campus policies and procedures to ensure compliance with Clery Act, and to improve our communication systems with all stakeholders. This process (updating policies and procedures) requires time as we have to take all updated policies and procedures through our shared governance structure before board approval.
Recommendations to Mount Saint Mary’s, Los Angeles
Recommendation 4
To ensure the accuracy and completeness of campus crime statistics that each institution reports to ED and includes in its annual security report, Mount Saint Mary’s should establish procedures by January 2025 for compiling the Clery Act statistics. These procedures should include the following:
- Listing all campus departments that maintain crime and incident data and protocols for obtaining data from those departments. Identifying all law enforcement agencies and obtaining all crime and incident data from those agencies.
- Procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics.
Status:
Not fully implemented
Date of implementation:
7/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU established procedures for compiling accurate & complete Clery Act (CA) campus crime statistics & will reduce all such procedures to writing by January 2025.These procedures include the following:(1) Listing all campus departments that maintain crime & incident data: Student Affairs, Title IX, Human Resources, and Safety Department (DS).Identifying & continuing to provide annual training for individuals who are considered a Campus Security Authority (CSA). Identifying the Interim Senior Director for Campus Safety & Emergency Management as the person ultimately responsible for obtaining data for inclusion in the daily crime log. Implementing protocols for obtaining data from the identified departments, establishing procedures that require departments to report all incidents to DS by email daily, so the DS can ensure all CA-reportable incidents are recorded in the Daily Crime Log and captured for purposes of reporting crime statistics. Implementing weekly meetings of identified departments to discuss incidents recorded during the week and ensure accurate & complete reporting .By January 2025, MSMU plans to purchase & implement central use of Clery Edge II software to track & manage all crime and CA reporting.(2) MSMU identified the LAPD as the appropriate law enforcement agency from which to obtain all crime & incident data for its three locations.MSMU has a MOU in place with the LAPD and a procedure by which it requests crime and incident data via a prepared form letter to the LAPD. Interim Senior Director interacted with the LAPD to increase the timeliness of LAPD’s response to MSMU’s request for crime data.(3) MSMU updated its incident reporting form and legal counsel conducted training for MSMU’s Safety Coordinator and certain members of the DS regarding use of the updated form and regarding the collection and recording of appropriate information at the time of an incident to facilitate an accurate determination of whether the incident is CA reportable.
Recommendation 8
To ensure that all crimes are recorded in the institution’s daily crime log, Mount Saint mary’s should develop procedures by January 2025 for its campus security office or campus police department staff to follow. These procedures should include the list of all institutional departments and law enforcement agencies from which the campus security office or campus police department obtain crime data to include in the institution’s daily crime logs. These procedures should also define who is responsible for obtaining data for inclusion in the daily crime log.
Status:
Not fully implemented
Date of implementation:
12/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU established procedures for compiling accurate & complete Clery Act (CA) campus crime statistics & will reduce all such procedures to writing by January 2025.These procedures include the following:(1) Listing all campus departments that maintain crime & incident data: Student Affairs, Title IX, Human Resources, and Safety Department (DS).Identifying & providing annual training for individuals who are considered a Campus Security Authority (CSA). Identifying the Interim Senior Director for Campus Safety & Emergency Management as the person ultimately responsible for obtaining data for inclusion in the daily crime log. Implementing protocols for obtaining data from the identified departments, establishing procedures that require departments to report all incidents to DS by email daily, so the DS can ensure all CA-reportable incidents are recorded in the Daily Crime Log and captured for purposes of reporting crime statistics. Implementing weekly meetings of identified departments to discuss incidents recorded during the week and ensure accurate & complete reporting .By January 2025, MSMU plans to purchase & implement central use of Clery Edge II software to track & manage all crime and CA reporting.(2) MSMU identified the LAPD as the appropriate law enforcement agency from which to obtain all crime & incident data for its three locations.MSMU has a MOU in place with the LAPD and a procedure by which it requests crime and incident data via a prepared form letter to the LAPD. Interim Senior Director interacted with the LAPD to increase the timeliness of LAPD’s response to MSMU’s request for crime data.
Recommendation 21
To ensure that they fully and adequately disclose all required policies in its annual security reports, Mount Saint Mary’s should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Status:
Not fully implemented
Date of implementation:
1/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU has established procedures to ensure full and adequate disclosure of all required policies in the annual security and fire safety report (ASFSR). Specifically, MSMU started to update its policies and practices in April 2024. MSMU has also contracted with an external consultant to serve as Clery Coordinator. The Clery Coordinator has reviewed and provided input on MSMU’s policies, practices, and programs, and works with all campus departments that maintain crime and incident data, including Student Affairs, Resident Life, Student Conduct, Title IX, Human Resources, Equity, Diversity and Justice, and the Safety Department. The Clery Coordinator is also responsible for compiling the ASFSR. The Clery Coordinator uses a software tool as a checklist to ensure the ASFSR includes all required disclosures. Using this process, MSMU will also ensure that all disclosures in the 2024 ASFSR have appropriate supporting stand-alone policies. Federal guidelines do not require completely separate policies and allows required policies to reside in the ASFSR, but MSMU understands the State prefers and recommends that the supporting policies be separate stand-alone policies. By January 2025, MSMU will ensure that all disclosures in the 2024 ASFSR have appropriate supporting stand-alone policies, and that such policies are posted on MSMU’s external website.
Recommendation 22
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, Mount Saint Mary’s should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Status:
Not fully implemented
Date of implementation:
1/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU has established procedures to ensure full and adequate disclosure of all required policies in the annual security and fire safety report (ASFSR). Specifically, MSMU started to update its policies and practices in April 2024. MSMU has also contracted with an external consultant to serve as Clery Coordinator. The Clery Coordinator has reviewed and provided input on MSMU’s policies, practices, and programs, and works with all campus departments that maintain crime and incident data, including Student Affairs, Resident Life, Student Conduct, Title IX, Human Resources, Equity, Diversity and Justice, and the Safety Department. The Clery Coordinator is also responsible for compiling the ASFSR. The Clery Coordinator uses a software tool as a checklist to ensure the ASFSR includes all required disclosures. Using this process, MSMU will also ensure that all disclosures in the 2024 ASFSR have appropriate supporting stand-alone policies. Federal guidelines do not require completely separate policies and allows required policies to reside in the ASFSR, but MSMU understands the State prefers and recommends that the supporting policies be separate stand-alone policies. By January 2025, MSMU will ensure that all disclosures in the 2024 ASFSR have appropriate supporting stand-alone policies, and that such policies are posted on MSMU’s external website.
Recommendation 23
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, Mount Saint Mary’s should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Status:
Not fully implemented
Date of implementation:
1/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU updated its incident reporting form and legal counsel conducted training in May 2024 for MSMU’s Safety Coordinator and certain members of the Safety Department regarding use of the updated form and regarding the collection and recording of appropriate information at the time of an incident to facilitate an accurate determination of whether the incident is Clery reportable. MSMU also contracted with an external consulting firm who provided CSA training in September 2024, including training on identifying, determining, and reporting if a crime or incident is Clery reportable. MSMU will continue to provide training on an annual basis.
MSMU has also contracted with an external consultant to serve as Clery Coordinator. The Clery Coordinator works with all campus departments that maintain crime and incident data, including Student Affairs, Resident Life, Student Conduct, Title IX, Human Resources, Equity, Diversity and Justice, and the Safety Department. She is a graduate of the National Association of Clery Compliance Officers and Professionals (NACCOP) Clery Compliance Certification program. She receives annual training at the NACCOP Conference each year in July and she participates in the Clery Compliance Officer Recertification program to maintain her certification. The Safety Coordinator will attend NACCOP annual trainings in July 2025.
Recommendation 24
Mount Saint Mary’s should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Status:
Not fully implemented
Date of implementation:
1/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
MSMU updated its incident reporting form and legal counsel conducted training in May 2024 for MSMU’s Safety Coordinator and certain members of the Safety Department regarding use of the updated form and regarding the collection and recording of appropriate information at the time of an incident to facilitate an accurate determination of whether the incident is Clery reportable. MSMU also contracted with an external consulting firm who provided CSA training in September 2024, including training on identifying, determining, and reporting if a crime or incident is Clery reportable. MSMU will continue to provide training on an annual basis.
MSMU has also contracted with an external consultant to serve as Clery Coordinator. The Clery Coordinator works with all campus departments that maintain crime and incident data, including Student Affairs, Resident Life, Student Conduct, Title IX, Human Resources, Equity, Diversity and Justice, and the Safety Department. She is a graduate of the National Association of Clery Compliance Officers and Professionals (NACCOP) Clery Compliance Certification program. She receives annual training at the NACCOP Conference each year in July and she participates in the Clery Compliance Officer Recertification program to maintain her certification. The Safety Coordinator will attend NACCOP annual trainings in July 2025.
Recommendation 25
To ensure that it fully complies with state law and best practices related to campus safety, Mount Saint Mary’s should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Not fully implemented
Date of implementation:
1/30/2025
Evaluator assessment status:
Pending
60-Day Agency Response
Beginning in spring, MSMU has been updating its policies, programs, and procedures to ensure that it fully complies with state law and best practices related to campus safety, focusing on any items that were listed partially complete or missing during the process of the state audit. We have made great progress with the best practices recommended by the State, even though some recommendations are not explicitly required by law.
Recommendations to Orange Coast College
Recommendation 5
To ensure the accuracy and completeness of campus crime statistics that each institution reports to ED and includes in its annual security report, Orange Coast should establish procedures by January 2025 for compiling the Clery Act statistics. These procedures should include the following:
- Listing all campus departments that maintain crime and incident data and protocols for obtaining data from those departments. Identifying all law enforcement agencies and obtaining all crime and incident data from those agencies.
- Procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
To ensure the accuracy and completeness of campus crime statistics, OCC has drafted a Clery Compliance Team (CCT) guideline, which intends to identify the members of the team and respective roles on Clery compliance. Additionally, a Clery Flowchart has been developed to guide the process.
The College’s compliance efforts also include the development of a District-wide document for college-sponsored student travel, study abroad, and field study programs. This guideline ensures consistent adherence to Clery reporting standards across Coast District Colleges. To support these efforts, the College has created a guideline statement to help compliance with Clery requirements for these programs.
The College has instituted bi-monthly (twice per month) Clery Compliance Committee meetings to review all incident reports. Each report is evaluated for Clery reportability, with the corresponding Clery rationale documented in Maxient (system used at the College for incident reporting and maintenance of all such records). Thus far, meetings have already taken place twice, and moving forward, bi-monthly (twice per month) meetings are scheduled beginning in October 2024.
As part of these meetings, the College is developing additional guidelines to ensure the accurate compilation of Clery Act statistics. These guidelines will include listing of all campus departments that maintain crime and incident data, protocols for obtaining this data, and identifying law enforcement agencies that provide crime data. Furthermore, the College is working to establish specific criteria that staff will use to determine whether to include a crime or incident in Clery Act statistics. The College is committed to finalizing these guidelines by January 2025.
Recommendation 9
To ensure that all crimes are recorded in the institution’s daily crime log, Orange Coast should develop procedures by January 2025 for its campus security office or campus police department staff to follow. These procedures should include the list of all institutional departments and law enforcement agencies from which the campus security office or campus police department obtain crime data to include in the institution’s daily crime logs. These procedures should also define who is responsible for obtaining data for inclusion in the daily crime log.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
OCC has initiated bi-monthly (twice per month) Clery Compliance Committee meetings to review incident reports, ensuring that each report is thoroughly evaluated for Clery reportability, with corresponding Clery rationale documented in Maxient (database the College uses for all incident reports). These meetings have already occurred twice, with bi-monthly meetings scheduled moving forward.
To meet the requirement of ensuring that all crimes are recorded in the institution’s daily crime log, the College is developing guidelines that the campus security office to follow as part of regular operations. These guidelines will include a comprehensive list of all institutional departments and law enforcement agencies from which crime data will be obtained. This will ensure that crime data is accurately recorded in the daily crime log.
As part of the College’s ongoing compliance efforts, the Clery Compliance Committee will establish guidelines identifying who is responsible for gathering data from various departments and agencies and ensuring its timely inclusion in the daily crime log. The College is committed to finalizing and implementing these guidelines by January 2025 to ensure compliance with Clery Act requirements.
Recommendation 26
To ensure that they fully and adequately disclose all required policies in its annual security reports, Orange Coast should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
To ensure full and adequate disclosure of all required policies in the ASR, the District is currently reviewing its agreement with its Clery Consultants for support on this project. This work will include developing a detailed checklist that identifies all required disclosures and the corresponding supporting policies. The College will ensure that its approach is thorough and compliant with Clery Act requirements and that all disclosures are accurately reflected in the ASR. The College will continue to work on this process in the coming months to meet the specified timeline of January 2025.
Recommendation 27
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, Orange Coast should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
Orange Coast College is in the process of facilitating the full revision of its campus policies and institutional practices but the process will not be complete by the October 1, 2024 deadline due to internal governance structures required for development or review/revision of Board Policies and Administrative Procedures, which apply across the District. The District has an established Board Policy (BP) and Administrative Procedure (AP)(BP and AP) subcommittee. The subcommittee, which is a district-wide participatory governance subcommittee with representation from all constituency groups, is charged with overseeing the review and revision of existing BPs and APs and development of new ones, as needed to ensure compliance with federal and state statutes, including the Clery Act. The District/College’s governance structure involves a comprehensive consultation process with all key stakeholders to include the Board of Trustees.
Several BPs and APs have been identified to review for Clery Act compliance. These include:
· BP/AP 3410 Prohibition of Discrimination and Harassment
· BP/AP 3435 Discrimination, Harassment, and Retaliation Complaints and Investigations
· BP/AP 3500 Campus Safety
· BP/AP 3515 Reporting of Crimes
· BP/AP 3520 Local Law Enforcement
· BP/AP 3910 Title IX Sex Discrimination and Sex-Based Harassment
· BP/AP 4300 Field Trips and Excursions
· BP/AP 5500 Student Code of Conduct
· New BP 3503 and AP 3503 Missing Student Notification are also being developed.
While the College is currently in the process of making the necessary revisions and has not completed the process, please note that the District/College is fully committed to updating its BPs and APs to ensure compliance with the Clery Act as recommended. As noted, the work is ongoing, and we anticipate substantial progress in the coming months.
Recommendation 28
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, Orange Coast should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Recommendation 29
Orange Coast should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Recommendation 30
To ensure that it fully complies with state law and best practices related to campus safety, Orange Coast should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
The District/College is working on updating its Board Policies (BPs) and Administrative Procedures (APs) to ensure all relevant BPs and APs are compliant with Clery Act. This effort includes developing a comprehensive checklist to identify all required BPs, APs, and programs outlined in Appendix D, as well as any additional best practices that may not be explicitly required by law but are recommended for optimal campus safety.
Recommendations to UC Santa Cruz
Recommendation 6
To ensure the accuracy and completeness of campus crime statistics that each institution reports to ED and includes in its annual security report, Santa Cruz should establish procedures by January 2025 for compiling the Clery Act statistics. These procedures should include the following:
- Listing all campus departments that maintain crime and incident data and protocols for obtaining data from those departments. Identifying all law enforcement agencies and obtaining all crime and incident data from those agencies.
- Procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
As our campus has prepared this year’s ASFSR, we have identified and documented our processes as it relates to the collection of Clery Act statistics. We have also sourced a document from the Clery Center to help us with developing tests for classifying crimes or incidents in our Clery Act statistics.
We are using these processes to establish procedures for compiling the Clery Act statistics. These procedures will include a listing of all campus departments that maintain crime and incident data, protocols for obtaining data from those department, a listing of all law enforcement agencies and a process for obtaining all crime and incident data from those agencies, and procedures for the specific tests that certain staff should use to determine whether to include a crime or incident in the Clery Act statistics. These procedures will be established before January 2025.
Recommendation 10
To ensure that all crimes are recorded in the institution’s daily crime log, Santa Cruz should develop procedures by January 2025 for its campus security office or campus police department staff to follow. These procedures should include the list of all institutional departments and law enforcement agencies from which the campus security office or campus police department obtain crime data to include in the institution’s daily crime logs. These procedures should also define who is responsible for obtaining data for inclusion in the daily crime log.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
Our campus is currently reviewing our process for adding items into the daily crime log. Based on this review, the campus is establishing written procedures for UC Santa Cruz Police Department and other campus staff involved in the process to follow. These procedures will include the list of all institutional departments and law enforcement agencies from which the UC Santa Cruz Police Department obtains crime data to include in our daily crime logs. These procedures will also define who is responsible for obtaining and processing data for inclusion in the daily crime log. These procedures will be established by January 2025.
Recommendation 36
To ensure that they fully and adequately disclose all required policies in its annual security reports, Santa Cruz should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
As our campus has prepared this year’s ASFSR, we have identified and documented our processes as it relates to the preparation of our annual security and fire safety report. We have developed a document which outlines the required disclosures along with space to reference the supporting policies. We are additionally developing written guidance for staff who prepare the ASFSR which will include a checklist of the process. This guidance and checklist will be finalized before January 2025.
Recommendation 37
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, Santa Cruz should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Status:
Not fully implemented
Date of implementation:
10/1/24
Evaluator assessment status:
Pending
60-Day Agency Response
As our campus has entered the final stages of preparing this year’s ASFSR, we are finalizing and have updated several campus policies, interim policies, procedures, and programs to ensure that UC Santa Cruz meets all requirements of the Clery Act. As of August 1st, the campus has adopted a missing residential student policy and procedures. Additional policies and interim policies will be adopted by October 1, 2024.
Missing Residential student policy and procedures available at https://studentsuccess.ucsc.edu/about/policies-procedures/index.html
Recommendation 38
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, Santa Cruz should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Recommendation 39
Santa Cruz should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Recommendation 40
To ensure that it fully complies with state law and best practices related to campus safety, Santa Cruz should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Not fully implemented
Date of implementation:
January 2025
Evaluator assessment status:
Pending
60-Day Agency Response
As our campus has entered the final stages of preparing this year’s ASFSR, we are finalizing and have updated several campus policies, interim policies, procedures, and programs to ensure that UC Santa Cruz meets all requirements of the state law as well as best practices. This will be completed by January 2025.
Recommendations to University of San Diego
Recommendation 31
To ensure that they fully and adequately disclose all required policies in its annual security reports, San Diego should develop guidance by January 2025 for staff preparing the annual security reports. This guidance should identify all required disclosures for the reports and should include a comprehensive checklist that lists each of the required disclosures and their necessary supporting policies, as we illustrate in Figure 4.
Status:
Not fully implemented
Date of implementation:
1/25/2025
Evaluator assessment status:
Pending
60-Day Agency Response
60-day update (10/1/2024): [Not Fully Implemented] We are currently still utilizing “Appendix C: Checklist for Campus Safety and Security Compliance” provided by ED in the 2016 handbook and are in in the process of updating our comprehensive checklist per the Audit Team’s recommendation
Recommendation 32
To ensure that the disclosures in its annual security reports accurately represent campus policies and institutional practices and that they are reporting reliable information to the public and to ED, San Diego should develop, adopt, or update by October 1, 2024, campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery Act.
Recommendation 33
To ensure that staff responsible for compiling Clery crime statistics and preparing the annual security reports—as well as staff who provide crime data and policy information to those individuals—are aware of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the Clery Act, San Diego should provide to its staff regular trainings by January 2025 on Clery Act requirements and on specific campus procedures for complying with the Clery Act.
Status:
Not fully implemented
Date of implementation:
1/25/2025
Evaluator assessment status:
Pending
60-Day Agency Response
60-day update (10/1/2024): [Not Fully Implemented] We are still in the process of developing a training schedule for the Clery Act Compliance Committee, and other CSAs on campus. Training updates include:
- Residential Assistants and Community Directors-CSA Training: August 21, 2024
- Department of Public Safety Annual Meeting- Clery Act Updates: August 26, 2024
- Clery Act Compliance Committee: August 29, 2024
- School of Law-CSA Training: November 21, 2024
Recommendation 34
San Diego should require and ensure that all staff responsible for compiling the crime data and the annual security reports regularly participate in regular trainings.
Status:
Not fully implemented
Date of implementation:
1/25/2025
Evaluator assessment status:
Pending
60-Day Agency Response
60-day update (10/1/2024): [Not Fully Implemented] We are still in the process of developing a training schedule for the Clery Act Compliance Committee, and other CSAs on campus. Training updates include:
- Residential Assistants and Community Directors-CSA Training: August 21, 2024
- Department of Public Safety Annual Meeting- Clery Act Updates: August 26, 2024
- Clery Act Compliance Committee: August 29, 2024
- School of Law-CSA Training: November 21, 2024
Recommendation 35
To ensure that it fully complies with state law and best practices related to campus safety, San Diego should develop, adopt, or update by January 2025 its campus policies, procedures, and programs to ensure that they comply with all requirements of state law shown in Appendix D. The institution should comply with these requirements as a matter of best practice even if the law does not explicitly require them to do so.
Status:
Not fully implemented
Date of implementation:
1/25/2025
Evaluator assessment status:
Pending
60-Day Agency Response
60-day update (10/1/2024): [Not Fully Implemented] We are working to identify any state required policies, procedures, and programs that are pending updates. The following updates have been finalized:
- Memorandum of Understanding between the University of San Diego and the San Diego Police Department (pending signatures)
- USD Title IX Policies:
- 2024 Title IX Policy Prohibiting Sex Discrimination and Sex-Based Harassment and Grievance Procedures
- 2020 Title IX Sexual Harassment Grievance Process
- Written Notice of Rights, Options, and Resources
