2024-032 Clery Act Requirements and Crime Reporting

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.