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Consistent with the statutory and regulatory framework, and interpretive principles, the Department will continue to apply the plain meaning of terms contained within each Clery requirement. The Department will accept an institution's reasonable interpretation of terms as long as those terms are defined clearly to individuals who review the campus' Clery Act reports. Suppose the Department believes that more specific definitions are required. In that case, it will engage in future negotiated rulemaking to ensure that institutions and the public can comment on those definitions.
Campus Security Authorities (CSAs): 34 CFR 668.46(a)
While not defined in the statute, regulations provide that CSAs include: campus police or security department personnel, individuals or organizations identified in institutional security policies, and individuals with security-related responsibilities. The definition at § 668.46(a)(iv) states that a CSA also includes an official "who has significant responsibility for student and campus activities." institutions should focus on the "significant responsibilities" of an employee when determining whether that employee is a CSA for Clery purposes. Clery purposes may or may not include employees who meet the definition of "any official…who has the authority to institute corrective measures" for Title IX purposes under 34 CFR 106.30(a).
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Professor -Washington Community Scholars' Center
Emergency Response, Evacuation Notifications, and Timely Warnings: 34 CFR 668.46(g)
Emergency Notifications
Most reports of significant emergencies or dangerous events are received through phone calls to EMU security personnel or local emergency responders. Occasionally emergency reports are received by others or through other communication channels. In these cases, EMU security needs to be notified of the emergency to ensure appropriate warnings of an event occurring on or imminently threatening campus are sent to community members.
Timely Warnings
In addition to emergency messaging, timely warnings, as defined by the Clery Act and reported to university CSAs, will be issued in response to an event --either on- or off-campus--which, in the judgment of the designated university representatives, constitutes a crime that has occurred or poses an ongoing threat to the campus community.
Dissemination of warnings
Many warning channels can be activated individually or through the consolidated EMU Alerts system.
The university maintains a robust emergency warning system. Below is a non-comprehensive list of available warning channels for use. Refer to Appendix A for a detailed description of each warning mechanism.
- EMU Alerts (including email messages, text messages, and web-page messages)
- ALERTUS desktop and hallway beacons
- Building fire alarms
- Other
Many factors are taken into account when deciding to disseminate warnings. Below are some broad considerations.
- Type of hazard
- Life, safety, and property protection
- Urgency
- Audience
- System(s) capabilities
Policy for Preparing the Annual Disclosure of Crime Statistics
Under the Clery Act, EMU must report to the Department and disclose crime and fire data in its Annual Security & Fire Fire Report (ASR)
EMU will report statistics for the three most recently completed calendar years. The university must also submit their crime statistics to the Department as part of the annual data collection and survey, including the number of Clery-defined crimes that occurred on or within its Clery Geography and are reported to local police agencies or campus security authorities (CSA). Clery Act reporting does not require the institution to initiate an investigation or disclose personally identifiable information (PII) about the victim.
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