Overview
During our audit period, the Massachusetts Maritime Academy (MMA) did not maintain a single daily crime log that listed all reported incidents (including Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act [Clery Act] crimes) that took place within MMA’s geography. The lack of a current and complete daily crime log could prevent stakeholders (students, employees, and the general public) from obtaining information about incidents within MMA’s geography. This could prevent them from accurately assessing risks to their personal safety and the security of their property and dealing properly with those risks. Further, noncompliance with the requirements of the Clery Act related to the maintenance of a daily crime log could result in MMA losing the opportunity to participate in federal Title IV programs.
As previously noted, MMA records information about incidents that take place within its geography in three different sources (TriTech, Colleague disciplinary action records, and Class I student offense files). According to MMA officials, the information in TriTech is MMA’s official daily crime log. However, Public Safety Office (PSO) staff members did not record in TriTech any of the 15 Clery Act crimes that we identified from MMA’s Class I student offense files. They also did not enter in TriTech the 112 Clery Act crimes that were recorded by the Student Services Office (SSO). These 127 Clery Act crimes, which occurred during calendar years 2017, 2018, and 2019, included criminal offenses, hate crimes, and Violence against Women Act (VAWA) violations.
Authoritative Guidance
Section 1092(f)(4)(A) of Title 20 of the United States Code (USC) states,
Each institution . . . that maintains a police or security department of any kind shall make, keep, and maintain a daily log, written in a form that can be easily understood, recording all crimes reported to [its] police or security department.
Section 668.46(f)(2) of Title 34 of the Code of Federal Regulations (CFR) states,
The institution must make an entry or an addition to an entry to the log within two business days . . . of the report . . . to the campus police or the campus security department, unless that disclosure is prohibited by law or would jeopardize the confidentiality of the victim.
Reasons for Issues
MMA does not have policies and procedures that require SSO staff members to identify and report all Clery Act crimes to PSO within two business days after they are reported to SSO. In addition, SSO staff members have not been trained on how to identify which reported incidents are Clery Act crimes and need to be reported to PSO. Finally, PSO only requested disciplinary action information from SSO once a year, when it compiled the crime statistics for MMA’s annual security reports (ASRs).
Recommendations
- MMA should develop policies and procedures that require its SSO staff to identify all Clery Act crimes and report them to PSO within two business days after they are reported to SSO.
- MMA should establish monitoring controls to ensure that these policies and procedures are followed.
- MMA should ensure that SSO staff members are properly trained on how to identify Clery Act crimes and report them to PSO staff members for inclusion in the daily crime log.
| Date published: | March 3, 2022 |
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