By Sandy Santangelo
If your Institution receives Title IV funds, you are required to publish and distribute, by October 1 of each year, a comprehensive Annual Security Report (“ASR”) that contains, at a minimum, all of the statistical and policy elements enumerated in 34 C.F.R. 668.46(b). The ASR must be distributed as a single document via U.S. Mail, campus mail, hand delivery, or by posting it on your Institution’s website. If you choose to post it on your website, you must distribute a notice to all students and employees that includes a statement of the report’s availability and a link to its exact electronic address, a description of its contents, as well as an advisement that a paper copy will be provided upon request.
The Annual Security Report must include statistics for incidents of crimes reported during the three most recent calendar years for criminal homicide, forcible and non-forcible sex offenses, robbery, aggravated assault, burglary, motor vehicle theft, and arson. It should also include statistics for certain hate crimes as well as arrest and disciplinary referral statistics for violations of certain laws pertaining to illegal drugs, illegal usage of controlled substances, liquor, and weapons must also be in the ASR for on-campus property, on-campus student residential facilities, certain non-campus buildings and property and certain adjacent and accessible public property.
The ASR should also include the Institution’s security policies, procedures, and the availability of programs and resources, such as the law enforcement authority, practices of campus police and security forces, and incident reporting policies. The school is required to have an Emergency Response Plan (ERP) and evacuation procedures in place and include these in the ASR. The ERP should discuss procedures for ‘Timely Warnings.’ This requires the Institution to have a plan implemented to alert all school personnel and students, both on campus and off-campus, of an active threat on campus. The Institution is required to conduct a test of their ERP Plan at each campus location on at least an annual basis.
Alcohol and drug policies and education programs are also required to be disclosed in the ASR. An alcohol and drug abuse prevention program must be in operation and distributed to all students, faculty and staff. The program and policies must be reviewed every two years to determine its effectiveness and to ensure all policies, disclosures, and crime statistics are current and in compliance with Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act requirements. Part of this review should include ensuring that the contact information included for alcohol and drug treatment centers is correct.
Volume 1, Issue 3