Chapter 5: Administration
- Adoption: 11/20/14
- Revised: 9/8/14
- Last Reviewed: 11/5/14 (SGC)
- President Approved: 11/20/14
- Next Review Date:
- Authority: Hennepin Technical College
- Custodian of Policy: Vice President of Administrative Services
Policy Statement
This policy identifies Hennepin Technical College’s Campus Security Authorities and delineates their responsibilities in fulfillment of the requirements contained in federal law, the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (“Clery Act”) and the Higher Education Opportunity Act (“HEOA”).
The Clery Act and HEOA require that HTC, and all other colleges and universities participating in federal student-aid programs, collect and disclose certain timely and annual information about campus crime and security policies. Typically, such crimes will be reported to HTC Campus Security or to local or state police authorities. However, a student who is the victim of a crime may be more inclined to report it to someone other than police or security officials. For this reason, the Clery Act requires that institutions collect crime reports from a variety of individuals and organizations considered to be Campus Security Authorities (CSAs).
Implementation Procedure
In order to maintain a safe and secure learning and working environment for students, employees, and visitors, Hennepin Technical College shall designate certain college officials as Campus Security Authorities (CSAs) in accordance with the Clery Act and HEOA. Designated CSAs shall assist in gathering crime data by reporting in a timely manner to the college’s Director of Security and Emergency Preparedness or designee all information of alleged criminal activity provided in good faith by any person. CSAs shall be trained in their responsibilities under the Clery Act, the procedures they are to follow, and the crimes they are required to report.
Nothing in this policy shall be interpreted to relieve any college employee receiving information of alleged criminal activity from reporting that information to HTC Security staff or a supervisor.
1. Designation of HTC Campus Security Authorities
The Clery Act identifies four categories of individuals and organizations that shall be designated as CSAs. The specific designations for HTC are listed below.
1.1 Campus Security Department Personnel
All members of the HTC Safety & Security Departments who have security-related responsibilities, whether directly employed by the college or contracted:
- Director of Security and Emergency Preparedness
- Director of Safety
- Security Officers (contract employees) Security Work Study students (student workers)
1.2 Other Individuals Responsible for Campus Security
College staff with responsibility for security who are not assigned to the HTC Campus Security Department:
- President
- Vice President of Administrative Services
- Director of Human Resources
- Executive Director of Institutional Advancement
- Director of Information Technology
1.3 Individuals & Organizations to Whom Reports Are Directed
College staff and organizations identified to receive reports of criminal activities in HTC’s Annual Security Report:
- Vice President of Academic & Student Affairs
- Director of Diversity/Affirmative Action
- Dean of Student Success Services
1.4 HTC Officials with Significant Responsibility for Student and Campus Activities
Other college officials to whom students may report/confide criminal activity:
- Dean of Enrollment Services
- Academic Deans (all)
- Director of Student Life
- Director of Enrollment and Veterans Services
- Disability Services Coordinators (2)
- Career Services Director
- Law Enforcement Center Director
- Academic & Personal Counselors and Advisors (except as noted below)
- Student Clubs and Organization Faculty & Staff Advisors
2. Exemption for Pastoral and Professional Counselors
The Clery Act provides an exemption for two types of individuals who, although they may have significant responsibility for student and campus activities, are not Campus Security Authorities under the Clery Act in certain situations: pastoral counselors and professional counselors. HTC does not employ pastoral counselors.
Professional counselors are exempt from acting as CSAs when their official responsibilities, as defined in the employee’s job description, include providing mental health counseling to members of the college community and when they are functioning within the scope of their license or certification. This category would include professional counselors who are under contract to provide mental health counseling for the college. The Clery Act does not exempt a person whose responsibilities include both academic and professional counseling when that person learns of a criminal incident while engaged in academic counseling.
3. Responsibilities
3.1 Vice President of Administrative Services
The Vice President of Administrative Services shall develop and promulgate procedures to implement this policy and shall have overall responsibility for coordinating the college’s program for complying with the provisions of the Clery Act and the HEOA. The Vice President of Administrative Services shall designate those individuals responsible for developing procedures, programs, and data collection, notices of timely warning or emergency notifications, and reports to comply with the Clery Act.
3.2 Director of Security and Emergency Preparedness
The Director of Security and Emergency Preparedness is responsible for coordinating the collection of crime data from the CSAs, for providing Clery Act training to the CSAs, for coordinating and posting of the Daily Campus Crime Reports, and for coordinating the preparation and posting of the HTC Annual Security Report.
3.3 Campus Security Authorities
CSAs shall report to the Director of Security and Emergency Preparedness any allegation of criminal activity reportable under the Clery Act that is made in good faith.
4. Procedures
The following procedures shall be followed in fulfilling the requirements of this policy.
4.1 Notification of Campus Security Authority Responsibilities
Clery Act annual crime reporting is based on the calendar year. The Director of Security and Emergency Preparedness will notify the college’s CSAs of their designation, the associated responsibilities, and the reporting process they are to follow to document Clery Act reportable incidents.
4.2 Training and Documentation
The Director of Security and Emergency Preparedness will provide bi-annual training to all CSAs on their responsibilities and any updates to the reporting requirements of the Clery Act and any other relevant law. Any new employee appointed to a position designated a CSA will receive the required training within 30 days of initial appointment. The Director will document the training and maintain the documentation in the Campus Security files.
4.3 Reporting Crimes Requiring Timely Warning
The Clery Act requires institutions to alert their campus communities in the event of certain crimes in a manner that is timely and will aid in the prevention of similar crimes. A CSA who becomes aware of a Clery Act crime that represents a serious or continuing threat to students or employees shall report that information immediately and by the most expeditious means to Campus Security, the Director of Security and Emergency Preparedness, or the Vice President of Administrative Services for determination of the need issue a campus or college-wide warning.
4.4 Collection of Information on Clery Act Reportable Incidents
A CSA who receives information regarding a Clery Act reportable incident will submit a report of the information to the Director of Security and Emergency Preparedness within twenty-four hours of receiving the information using the Campus Security Authority Crime and Incident Report Form (Appendix A). This requirement applies to a crime previously reported under the timely warning requirement described in 4.3 above. The Director of Security and Emergency Preparedness will review the reports for inclusion in the Daily Crime Reports, for the Annual Security Report, and, in consultation with the Vice President of Administrative Services, for issuing Timely Warnings or Emergency Notifications.
4.5 What Campus Security Authorities Should Not Do
College officials designated as CSAs who are not otherwise assigned such responsibilities are not responsible for:
- determining authoritatively whether a crime has taken place – this is a function of law enforcement;
- trying to apprehend the alleged perpetrator(s) of a crime – this is also a law enforcement function; or
- trying to convince a victim to contact law enforcement if the victim chooses not to do so. This does not relieve a college official of the responsibility for advising a victim of the limits placed on HTC’s ability to investigate or take disciplinary action in the event of an incident in which the victim is unwilling to assist in the college’s process.
5. Definitions
Clery Act Incident or Crime – criminal activity that is among the types of crimes or incidents that are required to be reported by the Clery Act and that occurs within the geography stipulated by that law relative to HTC. It is not necessary that the crime be investigated by law enforcement or a Campus Security Authority, nor must a finding of guilt or responsibility be made for the incident to be reported and disclosed in the college’s Clery Act crime reports.
College Official – any person who has the authority and duty to take action or respond to particular issues on behalf of the college.
6. References
- Code of Federal Regulations Title 34, § 668.46
- The Handbook for Campus Safety and Security Reporting (2011 ed.) Higher Education Opportunity Act of 2008
- Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) 20 U.S.C. § 1092(f)
7. Review Periodicity and Responsibility
The Vice President of Administrative Services shall review this policy at each anniversary of its approval and, if necessary, recommend revisions.
8. Effective Date and Approval
This is the first version of this policy.