Overview
CCCC did not have a formal process in place to determine which employees met the definition of a campus security authority (CSA) or to ensure that these employees were notified of and trained on their responsibilities. Although CCCC provided us with a list of six employees, each of whom it determined as meeting the definition of a CSA during the audit period, CCCC could not demonstrate the process used to make this determination or that these employees had received training on their responsibilities as CSAs.
If CCCC does not properly designate and train all CSAs, then CCCC’s ability to compile and report accurate annual crime statistics is limited, and, with inaccurately reported crime statistics, current and prospective students, CCCC employees, and members of the public may be misinformed or draw incorrect conclusions about campus safety.
Authoritative Guidance
According to 34 CFR 668.46(a), a CSA is defined as the following:
(i) A campus police department or a campus security department of an institution.
(ii) Any individual or individuals who have responsibility for campus security but who do not constitute a campus police department or a campus security department . . . such as an individual who is responsible for monitoring entrance into institutional property.
(iii) Any individual or organization specified in an institution’s statement of campus security policy as an individual or organization to which students and employees should report criminal offenses.
(iv) An official of an institution who has significant responsibility for student and campus activities, including, but not limited to, student housing, student discipline, and campus judicial proceedings. If such an official is a pastoral or professional counselor . . . the official is not considered a campus security authority when acting as a pastoral or professional counselor.
According to the Clery Act Appendix of the Federal Student Aid Handbook,
The Department [of Education] will defer to an institution’s designation of CSAs as authoritative and provide any technical assistance necessary to work with institutions to help ensure proper identification and notification of CSAs consistent with the regulations.
According to CCCC’s 2023 ASR, examples of individuals who are considered CSAs include the following:
CCCC CSA’s include student services personnel, the College’s affirmative action officer/Title IX coordinator, weekend/evening administrators, satellite campus managers, employees who monitor building access (i.e. designated Fitness Center personnel), and may include others whom CCCC recognizes as having a “significant responsibility for student and campus activities” as part of their regular duties.
Reasons for Issue
CCCC management could not explain why a formal process had not been established to determine which employees met the definition of a CSA and to train those employees. According to CCCC management, the six individuals who were CSAs during the audit period were identified by the former chief of police and public safety based upon this official’s experience.
CCCC did not have policies and procedures in place to ensure that all CSAs were trained in their responsibilities and that records of completion of this training were retained.
Recommendations
- CCCC should establish a process for its Human Resources Department and Department of Public Safety to identify individuals who meet the definition of a CSA.
- CCCC should maintain and regularly update a list of identified CSAs.
- CCCC should notify identified CSAs and train them on their responsibilities as CSAs at least annually and retain records of training completion for all CSAs.
Auditee’s Response
Cape Cod Community College (the College) acknowledges that, previously the College could not fully authenticate training delivered to Campus Security Authorities (CSAs) which although not required by Clery is best practice. The College is also currently improving the training and identification of the CSAs throughout the organization. Effective August 2024, the College partnered with an outside vendor to provide an array of necessary trainings for a core group of employees identified as CSAs. In 2025, this core group of CSAs was expanded. Additionally, the current Chief has formal training in the foundations of the Clery Act. The College has also established an ad hoc Clery Team to review the ASR. The College agrees with the recommendation that Human Resources and the Department coordinate on the identification and incorporation of the duties of CSA.
Learning from the audit findings, the College is moving forward with the following framework to ensure that the process behind the ASR is more robust.
- Identify multidisciplinary senior level representatives to comprise a Clery (compliance) Team.
- Designate an administrative assistant and/or compliance coordinator to support CSA recordkeeping, including CSA identification and training.
- Ensure that Clery Compliance team members have an adequate understanding of Clery regulations.
- Incorporate . . . CSA reporting form on College website.
Auditor’s Reply
Based on its response, CCCC is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | July 1, 2025 |
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