Overview
SSU could not provide us with a list of individuals who had been identified by the university as campus security authorities (CSAs), nor did SSU ensure that all CSAs received training on their responsibilities.
Based on our interviews with SSUPD, at one time SSU had a process to identify CSAs. According to the interim SSUPD chief of police, the last list of CSAs who were identified using this protocol was dated April 7, 2015.
Additionally, SSU did not have a process in place to notify all identified CSAs of their responsibilities and did not ensure that all identified CSAs received proper training. Although SSUPD could not provide a list of CSAs for the audit period, SSUPD provided us with sign-in sheets for CSA trainings that it held during the audit period. Our inspection of these sign-in sheets found that not all employee job titles, that SSU determined met the definition of a CSA in its 2023 ASR, were on these sign-in sheets. We found that some CSAs from the Resident Life and Student Life Departments attended the CSA training. However, several SSU job titles identified as CSAs in SSU’s 2023 ASR were not on the sign-in sheets. For example, SSU identified the director of athletics as a CSA in its 2023 ASR, but SSU’s director of athletics did not sign in for the relevant CSA training.
From these sign-in sheets, we could not verify that all CSAs attended the CSA trainings during the audit period. We also noted that SSU’s last reviewed list of CSAs, dated April 7, 2015, and the Clery Act include the following job titles that were not found on SSUPD’s CSA training sign-in sheets during the audit period: campus police officer, coaches or athletic administrators, and student group advisors.
If SSU does not properly identify and train all CSAs, SSU’s ability to compile and report accurate annual crime statistics is limited and, with inaccurately reported crime statistics, current and prospective students, SSU 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:
- A campus police department or a campus security department of an institution.
- 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.
- 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.
- 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 for 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 SSU’s 2023 ASR, examples of individuals who are considered CSAs include the following:
- A vice president for student life who oversee student housing, a student center or student extracurricular activities.
- A director of athletics, a team coach or a faculty advisor to a student group.
- A student resident assistant or a student who monitors access to dormitories.
- A coordinator of Greek Life.
Reasons for Issue
SSUPD’s interim chief of police told us that they had conversations with SSU Human Resources Department employees about making CSA identification part of SSU’s onboarding process. The Human Resources Department employees said SSUPD would need to create a list of job descriptions / responsibilities for which Clery Act training should be included. The previous chief of police had started working on this list of job descriptions / responsibilities; however, because of the time-consuming process of identifying who should be included on this list and rewriting job descriptions to include CSA responsibilities, they never completed the list.
Recommendations
- SSU should establish a process for its Human Resources Department and SSUPD to identify individuals who meet the definition of a CSA.
- SSU should maintain and regularly update a list of identified CSAs.
- SSU should notify identified CSAs and train them on their responsibilities as CSAs at least annually.
Auditee’s Response
We agree with the above finding. The university rearticulates the time period which the audit covered, mainly the entire [COVID-19] period. Both SSUPD and the office of human resources and equal opportunity (“HR”) were integrally involved in managing the impact of the pandemic on campus, including communications, employee and student testing, and data tracking. Unfortunately, during that time, the university’s attention was pulled away from the identification and training of CSA’s campus wide. SSU acknowledges that much of the CSA identification and training during and after the pandemic has been focused on student life administrators and staff. SSUPD and HR will undertake a review process to more fully identify all CSAs and will provide notification and training to those individuals annually. SSUPD will annually update the list of identified CSAs. The university utilizes Safe College online training to equip CSAs with knowledge and skills for effectively managing safety and compliance on campus.
Auditor’s Reply
Based on its response, SSU 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: | November 4, 2024 |
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