Clery Act Enforcement: October 1, 2017 Deadline for Colleges and Universities to Complete and Distribute Annual Security Report Fast Approaching (Duane Morris)

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, or Clery Act, 20 U.S.C. § 1092(f) (34 C.F.R. § 668.46), requires all schools, colleges and universities that participate in federal student financial aid programs to:

1. Maintain and disclose to the public statistics, policies and programs about certain crimes occurring on and/or near a campus; and
2. Have in place and be able to demonstrate implementation of specific campus safety policies, including those related to crimes of sexual violence.

Educational institutions must provide and distribute this information in a Clery Act Annual Security Report (ASR) by October 1, 2017. U.S. Department of Education guidance specifies that this is a firm deadline; there is no grace period and no exemptions exist.

ASR requirements include:

• Policy Statements: Institutions are required to include the procedures, practices and programs utilized to keep students and employees safe and the facilities secured. Institutions should review the content of the ASR to ensure that required policy statements are in conformance with the law and that staff members understand how those policies are implemented.
• Clery Act Crime Statistics: The ASR includes Clery Act statistics for the prior three calendar years. For the 2017 ASR report, this includes calendar years 2014, 2015 and 2016 crime statistics and the sexual violence and other campus safety policies required by the Clery Act. All statistics, other than hate crimes and unfounded crimes, should be presented in a tabular form.
• Institutions with on-campus student housing facilities must include an additional policy statement that addresses missing student notification. In addition, institutions with on-campus student housing facilities must publish an annual fire safety report, which may be included in the Clery Act ASR, provided that the title of the document clearly states the inclusion of both reports.

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