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Clery Audit Report by D. Stafford and Associates for the University of Connecticut
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D. Stafford & Associates
University of Connecticut Clery Audit Draft Report 1
University of Connecticut Clery Act/HEOA Review
September 21, 2012
Submitted by: Dolores A. Stafford
Table of Contents
Overview
Section I: Geography/Campus Map
Section II: Local/State Police Department Statistics
Section III: Timely Warning Notice
Section IV: Distribution of Compliance Document to Current Students/Employees
Section V: Distribution of Compliance Document to Prospective Students/ Employees
Section VI. Gathering Statistics from Campus Security Authorities
Section VII: Separate Campuses
Section VIII: Daily Crime Log
Section IX: Education Programs: Security Awareness/Crime Prevention
Section X: Emergency Response/Communication
Section XI. Emergency Test (Exercise and Drill)
Section XII: Fire Safety Report and Fire Log
Section XIII: Missing Persons
Section XIV: Records Retention
Section XV: Reported Statistics (Charts)
Section XVI Audit of UCONN PD Criminal Incident Reports
Section XVII: Audit of the Office of Community Standards Records and Processes
Section XVIII: Overall Recommendations
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University of Connecticut Clery Audit Draft Report 2
Overview
Overall, the institution has tried to comply with many of the requirements of the Clery
Act. It is obvious that Captain Averna spends a considerable amount of time compiling
the information that needs to be published in the Annual Security and Fire Safety Report.
She was very much engaged in the audit process and was extremely helpful throughout
our time on campus. We believe that she benefited from the one-on-one training that she
received during the audit process. We were impressed with the willingness of Chief
O'Connor and her staff to implement all of the suggested recommendations that we made
throughout our time on campus. If all of the recommendations are implemented, there is
no doubt that the University of Connecticut will be a model agency in terms of
compliance with the Clery Act.
The institution has some areas of non compliance, as identified within this report. Some
are more significant issues than others, but the Department of Education focuses on the
details of compliance when they conduct Clery Act audits, so the areas of non
compliance that may appear to be minor issues are treated the same as the more serious
issues. All of the issues of non compliance can result in a fine of $27,500 per violation
and as such, all of them need to be rectified.
When we arrived, we would estimate that the institution was in the 60-70% range in
terms of being in total compliance with all of the requirements of the Clery Act. In
comparison to other institutions that we have audited, the institution made a strong good
faith effort to comply with the requirements of the Clery Act. There were some errors and
omissions, as described within this report and the report previously submitted to the
institution regarding the Annual Security and Fire Safety Report, but most of them were
caused by a lack of understanding of some of the nuances of this complex law.
We made 75 recommendations in this report to improve your process and methodology
for complying with the Clery Act/HEOA security and safety requirements. All
recommendations contained in this report are underlined.
Section I: Geography/Campus Map
The University of Connecticut Police Department (UCPD) did not have an official Clery
Map of the campus, which caused some significant errors in counting crimes as having
occurred on public property instead of correctly counting them in the on campus
geographic section of the crime statistics chart. We identified the boundaries of the core
campus and created an initial Clery map based on the information provided to me by
Captain Averna and Lt. Vargas about the ownership, control and property lines of the
institution. The current map needs to be enhanced to reflect all roads, for example
Hunting Lodge Rd. and Separatist Rd. are missing from the map. UCONN has a written
agreement with CT DOT to maintain and control the North Eagleville Rd. from Rte. 195
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University of Connecticut Clery Audit Draft Report 3
to Hunting Lodge Rd. They have designated that UCONN manages that road. This
written agreement needs to be filed in the Clery Administrative file.
The UCPD has a list of campus buildings that provides an specific information about
whether each building is being counted as on campus property or non campus property.
This list is helpful, as it explains the map in narrative terms. UCPD needs to obtain a new
list of campus buildings and their usage from the Real Estate Office to allow the PD to
verify the accuracy of their current list.
We reviewed the Comprehensive Sign Plan for the Control of Traffic document that
clarifies the agreement between the University of Connecticut and Connecticut State
Traffic Commission. The agreement indicates that the institution controls the majority of
streets that are immediately adjacent to or run through the campus. The three streets that
were identified (for purposes of this audit) as public streets are Storrs Road (Rt 195),
South Eagleville Road, and Gurlyville Road from Storrs to campus boundary.
The campus representatives indicated that:
the institution has non-campus properties associated with the main campus.
the campus has public streets running through or immediately adjacent to the
campus boundaries and they have been identified on the new Clery map.
the campus does not have any public parking facilities within the core campus
boundaries or immediately adjacent to campus. NOTE: The new building on Dog
Lane is scheduled to have a municipal parking facility so the institution will need
to request crime statistics for that facility and report them under the public
property statistics once the facility is operational.
the campus does not have any public parks within the core campus boundaries or
immediately adjacent to campus.
the campus does not have any public transit stations or stops within the core
campus boundaries or immediately adjacent to campus.
the campus does not any public waterways within the core campus boundaries or
immediately adjacent to campus.
The Daily campus building and the sororities in Husky Village are currently owned or
controlled by UCONN and these properties are within the core campus boundaries.
Crimes reported for those locations have been correctly captured under the on campus
and residential facilities locations in the crime statistics. There are also two student
organizations that own or control property outside of the core campus (Sigma Alpha
Epsilon and Alpha Gamma Rho) and the crime statistics for those locations were
correctly being reported under the non-campus location in the crime statistics.
UCONN does not currently have a procedure in place to automatically notify the UCPD
when the institution buys, sells or leases property.
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University of Connecticut Clery Audit Draft Report 4
Recommendation 1.1: Develop an approved Clery map for internal use that identifies
and clarifies the boundaries of the campus or the “core campus” for Clery purposes. The
map should clearly identify the public streets that are immediately adjacent to or running
through the campus, that are required to be captured under the Public Property category.
Recommendation 1.2: Review the final draft of the map with the General Counsel’s
Office and the UCONN Real Estate Office to ensure that all three offices are in
agreement about the accuracy of the map. In a Department of Education Audit, the
auditors have been known to interview people in those offices about the accuracy of the
map.
Recommendation 1.3: As property is bought, sold or the use changes, the UCPD should
be automatically notified by the UCONN Real Estate Office to allow that office to update
their Clery map and building list.
Recommendation 1.4: Provide the Clery Map and completed building list to the Office of
Community Standards when it is approved and anytime it is updated.
Recommendation 1.5: Compare the list of campus buildings with the newly developed
Clery map to ensure that all of the "Clery Designations" are accurate and consistent with
the map.
Section II: Local/State Police Department Statistics
The UCONN Police Department currently sends a written request for crime statistics to
the Connecticut State Police (they run the Mansfield Police Department). They receive
statistics from the State Police on an annual basis, but they have only been counting the
statistics that they receive for the two non campus sororities. They have not been
counting what is provided to them for other areas in the core campus, such as Storrs Road
(Rt 195) and South Eagleville Road.
Recommendation 2.1: Count all crimes that are reported by the State Police for all
property within the core campus that is owned or controlled by UCONN, the public
property that runs through or immediately adjacent to the core campus and any non-
campus properties associated with the institution.
Recommendation 2.2: Send a written request for crime statistics to each police
department with jurisdiction for each separate/branch campus. Each written request
should include a list the specific addresses of the locations that institution owns, leases or
controls; any public property running through or immediately adjacent to the campus
facilities (list the specific hundred blocks); and any non-campus properties associated
with each separate/branch campus.
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University of Connecticut Clery Audit Draft Report 5
Recommendation 2.3: Send a letter annually and/or any time there is a change in the
leadership of any of the law enforcement agencies that you request statistics from,
informing them about the timely warning notice requirement, and make a formal request
that they notify UCPD immediately if a crime is reported to them that could pose a
serious, ongoing threat to the campus community.
Recommendation 2.4: Letters/emails sent to local law enforcement and their written
responses should be maintained on file for seven years (the standard records retention
period for all Clery Act related documents). If they call you to respond verbally to the
request, obtain a written response via letter or email for your file.
Recommendation 2.5: Enhance the letter being sent to local law enforcement to clarify
the Clery crimes and the geography for the requested crime statistics. See appendix #1 for
sample language to enhance the letter.
Appendix #1—Local Law Enforcement Letter
Section III: Timely Warning Notice
The timely warning notice statement that was published in the Annual Security/Fire
Safety Report (ASR) was insufficient and recommendations for enhancing the description
of the process were included in the ASR Review that was previously submitted to UCPD.
The ASR was missing two key components, which included the circumstances for which
a warning will be issued and the individual or office responsible for issuing the warning
(who writes it and who initiates it). The timely warning email messages that we reviewed
provided the facts about the crimes that were reported, but the institution needs to make
sure that each timely warning notice contains information that would assist in the
prevention of similar crimes, thus the message should include at least one crime
prevention tip--either something you want the reader to do or not to do--in terms of
potentially preventing a similar occurrence.
In the interviews with UCONN Police staff, they indicated that the department is in the
process of developing a standard operating procedure that will govern the distribution of
timely warning notices.
Recommendation 3.1: Develop a timely warning notice protocol/standard operating
procedure. The procedure needs to start at the point of a serious crime being reported to
the UCPD. The protocol needs to address the circumstances that will trigger a warning,
who is responsible for developing the warning, who is responsible for disseminating the
warning, and the method of disseminating warnings.
Recommendation 3.2: File a copy of each timely warning notice with each incident
report that prompts an alert. This will be beneficial in the event of a future audit.
Recommendation 3.3: Maintain timely warning notices on file for seven years (the
standard records retention period for all Clery Act related documents).
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Recommendation 3.4: Each timely warning notice must contain information that would
assist the community in the prevention of similar crimes. Make sure each email message
includes at least one crime prevention tip or tell them what they should or should not do.
Appendix #2—Timely Warning SOP Sample
Appendix #3—Timely Warning Publication Determination Form
Section IV: Distribution of Compliance Document to Current Students/Employees
All faculty, staff and students are required to have a University of Connecticut email
address. The campus sends a blast email each year to all students and employees to notify
the campus community of the availability of the Annual Security and Fire Safety Report.
I requested a copy of the notice that was sent to the UCONN community in the Fall of
2011 and Fall 2010. The notice included a statement of the report's availability and a
brief description of the contents. The notice did not include the exact electronic address
of the report or a statement that a paper copy will be provided upon request, as required.
Recommendation 4.1: Revise the notice to include a direct URL to the Annual Security
and Fire Safety Report (the PDF of the complete report).
Recommendation 4.2: Revise the notice to include a statement that a paper copy will be
provided upon request.
Section V: Distribution of Compliance Document to Prospective Students/Employees
I reviewed the following admissions applications/materials on the UCONN website:
Undergraduate Admissions, Freshmen
Undergraduate Admissions, Transfer
Center of Continuing Studies
Graduate Admissions
International Students
MBA and EMBA
School of Dental Medicine
School of Law
School of Medicine
School of Social Work
I did not see the required notice on any of these sites where individuals apply for
admission to various programs. The notice of availability must be provided to all
prospective students.
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University of Connecticut Clery Audit Draft Report 7
The notice must include a statement of the report's availability; a statement that a paper
copy will be provided upon request and how to obtain a hard copy; a brief description of
the contents; and the exact electronic address of the report.
The Clery compliance officer has not routinely reviewed the admissions materials for the
various undergraduate and graduate programs to ensure that the required notice is being
provided to prospective students. One of the hard copy admissions applications
(undergraduate) that I was provided contained a notice for prospective students, which
included a statement of the report's availability and a statement that a paper copy will be
provided upon request. It did not include a list and brief description of the contents and
the exact electronic address of the report.
Recommendation 5.1: Gather all admissions application materials to determine (verify)
whether or not the required notice is contained within those materials (in hard copy or in
the on line versions).
Recommendation 5.2: Provide the required language for the notice of availability to the
appropriate office(s) to be put on the website application for admission to each program
that has a separate and distinct application process. Request that the statement
immediately be added to any admissions materials on their websites and request that the
statement be added to the hard copy documents the next time they are printed.
Recommendation 5.3: Add a statement that provides a list and brief description of the
contents and the exact electronic address of the report to the notice of availability in the
hard copy of the Undergraduate Admissions Application.
Recommendation 5.4: Provide the required language for the notice of availability to the
Human Resources Department. Request that the statement immediately be added to the
employment application on their website and request that the statement be added to the
hard copy application, if applicable.
Recommendation 5.5: Conduct an annual audit of the admissions and employment
applications. Request all admissions materials in January of each year or print them from
the websites and review them thoroughly to verify that the required notice is included in
each application package or prospectus. I recommend the same course of action regarding
the employment application. You should flag the notice contained in each application and
maintain all of those documents in your annual administrative file in the event of a future
audit.
The required statement must include:
Notice of the report's availability
Description of the content of the report
Opportunity to request a copy.
Exact URL where report is posted
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University of Connecticut Clery Audit Draft Report 8
SAMPLE STATEMENT
University of Connecticut is committed to assisting all members of the community in providing for their
own safety and security. The annual security and fire safety report is available on the UCONN PD website
at (PUT DIRECT LINK TO ASR HERE).
If you would like to receive a hard copy of the Annual Security and Fire Safety Report which contains this
information, you can stop by the UCONN Police Department AT ????? or you can request that a copy be
mailed to you by calling ????.
The website and report contains information regarding campus security and personal safety including topics
such as: crime prevention, university police law enforcement authority, crime reporting policies, fire safety,
disciplinary procedures and other matters of importance related to security on campus. They also contain
information about fire statistics in UCONN Residence Halls and crime statistics for the three previous
calendar years concerning reported crimes that occurred on campus; in certain off-campus buildings or
property owned or controlled by UCONN; and on public property within, or immediately adjacent to and
accessible from the campus.
This information is required by law and is provided by The University of Connecticut Police Department.
Section VI. Gathering Statistics from Campus Security Authorities
The institution has not been gathering crime statistics from Campus Security Authorities.
The institution needs to come into compliance with this requirement as soon as possible.
This is a significant issue of non-compliance.
When determining the list of Campus Security Authorities, the institution must include
all individuals who have responsibility for student and campus activities. Include the
people in the following positions and those people who have as one of their functions the
responsibility of building relationships with students under the auspices of student and
campus activities:
Resident Assistants, Resident Directors, and Community Directors
Dean of Students Office (Leaders in Student Affairs and Housing)
Athletic Directors and Coaches (including Assistant ADs and Assistant Coaches)
Faculty or Staff Advisors to Student Organizations on Campus
Access Monitors (any professional or student staff members who monitor access
into campus buildings, including residential facilities, academic/administrative
facilities or parking facilities)
Contract Security Officers
Event Security Officers
Staff who provide safety escorts on campus (professional and student staff)
Staff in the Student Center or Student Union Building
Staff in the Student Activities Office (handling extracurricular activities)
Coordinator of Greek Affairs (or related positions)
Administrators at Branch/Satellite/Separate Campuses
Title IX Coordinator(s)
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Study Abroad Administrators
A physician in a campus health center, a counselor in a campus counseling center,
or a victim advocate in a campus rape crisis center if they are identified by your
school as someone to whom crimes should be reported or if they have significant
responsibility for student and campus activities.
Recommendation 6.1: Develop a list of all campus security authorities for the institution.
Include all individuals who have responsibility for student and campus activities. Include
the people in the positions identified above or those with functions of building
relationships with students under the auspices of student and campus activities.
Recommendation 6.2: Send a letter/email in January of each year to all CSAs to request
information about crime statistics for the previous calendar year (if you wait until
October of each year, ten months will have passed since the end of the previous calendar
year). The letter/email should include information about the obligations of CSAs to
immediately report a crime so it can be assessed to determine if a timely warning notice
should be distributed to the community and include a statistics chart for them to fill out
with the letter/email that includes the Clery crime definitions
Recommendation 6.3: Send the letter/email annually (in December) to all Campus
Leaders (Deans, Directors, and Department Heads) to notify them of the definition of
Campus Security Authority and to request their assistance in identifying staff members
within their areas of responsibility who may fit the definition.
Recommendation 6.4: Train all Campus Security Authorities in their responsibilities as a
CSA. NOTE: There is an on line training system available for purchase on the D.
Stafford & Associates website. The campus can buy a training center and manage the
training and records through this system. For more information go to
www.dstaffordandassociates.com
Recommendation 6.5: Add language to the agreements governing the Contract Security
Companies used by the institution on an on-going basis or for event security (when they
come up for renewal). In the interim, add language in the renewal letter to educate the
company about the fact that their employees, when working at University of Connecticut
or UCONN events, are campus security authorities and require them to put language into
their Standard Operating Procedures that are read by the contract officers or event
security officers working at the campus.
Suggested Language for Contract Security
When XXX Contract Security Company personnel are working at the University of
Connecticut (UCONN), they are considered Campus Security Authorities by a Federal
Law, the Jeanne Clery Disclosure of Campus Security Policy and Crime Statistics Act. As
such, any employee of the company who works at any location that is owned, leased or
controlled by UCONN is required to immediately report any crime reported to him/her to
the reporting structure of the institution, which is the UCONN Police Department. The
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University of Connecticut Clery Audit Draft Report 10
XXX Contract Security Company must add this requirement to the Standard Operating
Procedures that are read by the officers and supervisors who work on site on UCONN
owned, leased or controlled properties.
Recommendation 6.6: As a best practice, the Residence Hall staff (such as the Resident
Assistants) should also receive the email in the summer during their training period, so
that they are aware of their reporting responsibilities as they start their position for the
new academic year.
Appendix #4—Letter to Campus Security Authorities
Appendix #5—Crime Statistics Reporting Form that should be distributed with Appendix
#4
Section VII: Separate Campuses
The institution has been complying with the requirements for separate campuses for the
six branch campuses, which includes, Avery Point, Hartford Law, West Hartford,
Stamford, Waterbury, Torrington for which they have a separate Annual Security Report.
We conducted an assessment of the other off campus sites to determine if each of them
fits the revised definition of a separate campus, as defined in the 2011 Department of
Education Handbook. The campus has been complying with the Depot Campus
as part of the main campus in Storrs. We would recommend that the institution comply
with the Depot Campus as a separate campus, as it is not immediately contiguous to the
main campus, some classes are held there leading to a degree or other educational
credential and there are administrators on site at that location. It is clear that in the
marketing of the location, including the signage at the entrance to the campus, that the
institution considers this a "campus" and as such, at a minimum, the institution should
report separate crime statistics for that campus. The Annual Security and Fire Safety
Report (ASR) for the main campus could be identified (in an introduction) as complying
with the Main Campus and the Depot Campus. This would be the easiest way to comply
with the requirements of a separate campus for that location, as we were told all of that
the policy statements for both campuses are the same. That being said, the institution
would simply need to report the crime statistics for that location in a separate crime
statistics chart in the ASR.
Recommendation 7.1: Treat the Depot Campus as a separate campus for Clery reporting
purposes. The revised criteria of a “Separate Campus” as defined in the 2011 Clery
Act Handbook, includes locations offering a “organized program of study” and
having at minimum of one “administrator on site” working at that location. (The
Handbook states: “Administrative personnel encompass a variety of individuals who may
have some responsibility for the activities that take place at the location, for example, a
director, a building coordinator, a registrar, or a secretary”).
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Recommendation 7.2: Conduct an assessment of all University of Connecticut non
campus properties to determine if any of those locations meets the definition of separate
campus under the Clery Act.
Recommendation 7.3: Include a statement in the Annual Security and Fire Safety Report
that notifies the consumer that: all policy statements included in the report pertain to both
campus locations unless otherwise stated.
Recommendation 7.4: Send a request to the administrator at each campus/site to request
that they inform everyone at their location who fits the definition of campus security
authority about their responsibility to notify UCONN Police Department if they are
notified about any crimes that occur at the site. Notify the administrator about his/her
responsibility to notify UCPD in the event that they are notified of a serious crime so
UCPD can post a timely warning notice.
Recommendation 7.5: Develop Clery map for each separate campus and a narrative list
of all UCONN buildings and property at each campus. Keep this on file and update it
annually.
Section VIII: Daily Crime Log
The UCONN Police Department maintains a daily crime log with all of the required
categories. The specific information reported to UCPD by the Office of Community
Standards and the local police agencies has not previously been added to the daily crime
log. Once the incidents are reported to UCPD, the personnel there have two business days
to add that information into the daily crime log.
We were told that the officers investigate most crimes and they are responsible for
changing the dispositions in the LEAS system when they close a case or the disposition
changes. The process that was described causes some level of concern, as this important
requirement is currently the responsibility of one of many officers who may be assigned
the responsibility to investigate a crime. This system leaves significant room for error and
the administration should test the system to see if the officers are actually updating the
dispositions within two business days as required. If not, there may be a need to
streamline the process to ensure full compliance.
Four of the six separate campuses security/police officers working on site and thus, the
institution must maintain a daily crime log at those locations. These campuses include
Avery Point, Hartford Law (West Hartford is a satellite location of Hartford Law),
Stamford, Waterbury (Torrington is a satellite location of Waterbury). There is a hand
written daily crime log maintained at each of the four police sub-stations, as required by
the law.
The UCONN police officers technically have jurisdiction in the town of Mansfield. It is
our understanding that the officers may be periodically called upon to provide mutual aid
for the local/state police agencies, but that generally the police officers do not patrol
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beyond the campus borders and do not respond to calls for service outside the campus
boundaries. The UCONN Police Department should develop a standard operating
procedure or policy describing the technical jurisdiction of the officers and how they
come by that jurisdiction. The SOP should also address the institution's expectations and
limitations placed on the officers, i.e. to patrol the campus and respond to calls on the
campus property. Otherwise, any incident that the officers respond to outside the campus
boundaries (which we understand does not occur on a regular basis) must be addressed in
the daily crime log. (NOTE: This issue was raised in the ED audit of Yale University
because they "technically" have jurisdiction in the city of New Haven).
Recommendation 8.1: Develop a process to include the incidents reported directly to
Office of Community Standards in the daily crime log within two days of being received
by UCONN Police Department.
Recommendation 8.2: Develop a process to include the incidents reported directly to the
local police agencies in the daily crime log within two days of the information being
received by UCONN Police Department.
Recommendation 8.3: Develop a standard operating procedure or policy describing the
technical jurisdiction of the officers and how they come by that jurisdiction. The SOP
should also address the institution's expectations and limitations placed on the officers,
i.e. to patrol the campus and respond to calls on the campus property.
Recommendation 8.4: Develop a standard list of dispositions, define them for the
consumer and publish those on the website and place a copy in the front of the hard copy
book as part of the instructions for the crime log. If a disposition changes within 60 days
of the crime log entry, someone must be assigned to update it within 2 business days.
Recommendation 8.5: Do not use the term "Police Information" "Agency Assist" or other
generic terms under the "Nature" column in the crime log. The department must indicate
the specific criminal violation for all crime log entries.
Appendix #6: Crime Log Instruction Sample
Section IX: Education Programs: Security Awareness/Crime Prevention
The annual security report included a solid description of the crime prevention and
education programs that are presented to the campus community. The description also
provided information about the frequency of the programs, as required by law.
Section X: Emergency Response/Communication
UCONN did not address any of the other required policy statements regarding emergency
response, evacuation or immediate notification in the Annual Security and Fire Safety
Report published in 2011.
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University of Connecticut Clery Audit Draft Report 13
The following policy statements were missing (as outlined in the previously submitted
Report that assessed the contents of the Annual Security and Fire Safety Report):
A statement of current campus policies regarding immediate emergency response
and evacuation procedures.
A statement that the campus will immediately notify the campus community upon
the confirmation of a significant emergency or dangerous situation involving an
immediate threat to the health or safety of students or staff occurring on the
campus.
Include a list of the titles of the person(s) or organization(s) responsible for
providing a description of the process the institution will use to confirm that there
is a significant emergency or dangerous situation.
Include a list of the titles of the person(s) or organization(s) responsible for
providing a description of the process the institution will use to determine the
appropriate segment or segments of the campus community to receive a
notification.
Include a list of the titles of the person(s) or organization(s) responsible for
providing a description of the process the institution will use to determine the
content of the notification.
Include a list of the titles of the person(s) or organization(s) responsible for
providing a description of the process the institution will use to initiate the
notification system.
If there is an immediate threat to the health or safety of students or employees
occurring on campus, describe how the institution will provide follow-up
information to the university community.
A statement that the institution will, without delay, and taking into account the
safety of the community, determine the content of the notification and initiate the
notification system, unless issuing a notification will, in the professional judgment
of responsible authorities, compromise efforts to assist a victim or to contain,
respond to, or otherwise mitigate the emergency.
Indicate procedures for disseminating emergency information to the larger
community, i.e. neighbors who live near the campus, parents, etc.
Publicize the procedures to test emergency response and evacuation procedures in
conjunction with at least one test on an annual basis.
The UCONN Police Department is in the process of developing a Standard Operating
Procedure for Emergency (Immediate) Notification of the community in the event of an
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incident that poses an immediate threat to the health and safety of the UCONN
community.
Recommendation 10.1: Address all of the required policy statements identified above in
the 2012 version of the Annual Security and Fire Safety Report.
Recommendation 10.2: Develop a Emergency (Immediate) Notification protocol/standard
operating procedure. The procedure needs to start at the point of an immediate threat
being reported to UCPD and needs to include the circumstances that will trigger a
message being sent to the community, who is responsible for developing the message,
and who is responsible for sending the message. The protocol should also include a
process about follow-up messages and how follow-up information will be distributed to
the community.
Recommendation 10.3: Add all of the required policy statements to the Emergency
(Immediate) Notification Standard Operating Procedure that were added to the Annual
Security and Fire Safety Report to get the institution into compliance with the
requirements of the law.
Section XI: Emergency Test (Exercise and Drill)
The University of Connecticut is not in compliance with the requirement to conduct at
least one test of the emergency response and evacuation procedures each year. I found no
evidence that the institution has conducted a test that would meet the HEOA guidelines,
since the requirement went into effect in 2008. A required objective for the annual
exercise portion of the test must include addressing emergency response and evacuation
on a campus-wide scale. This means the institution must discuss how they would
evacuate the campus if that course of action was deemed necessary (you are not required
to actually evacuate the campus).
NOTE: A Test is defined by the HEOA as regularly scheduled drills, exercises, and
appropriate follow-through activities, designed for assessment and evaluation of
emergency plans and capabilities. A “drill” is defined as an activity that tests a single
procedural operation (e.g., a test of initiating a cell phone alert system or a test of campus
security personnel conducting a campus lockdown). An “exercise” is defined as a test
involving coordination of efforts (e.g., a test of the coordination of campus administrators
who oversee key units and first responders including police, firefighters, and emergency
medical technicians). Exercises are defined as tabletop, functional or full scale (live)
exercises designed to evaluate the emergency response plans of the institution. The
institution must complete a drill and exercise on an annual basis to meet the requirements
of completing a "test" per HEOA.
UCONN has not met the requirement of publicizing the emergency response and
evacuation procedures in conjunction with at least one test per year (a test is defined as an
exercise and a drill-which must be conducted in close proximity to each other at least
once a year to meet this requirement). This publication must be distributed to the
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UCONN community at least once each calendar year immediately following the
completion of all components of the test.
Recommendation11.1: Conduct a test of the emergency response and evacuation
procedures on an annual basis. As part of the test, the institution must conduct an exercise
and drill). (NOTE: A Test is defined as regularly scheduled drills, exercises, and
appropriate follow-through activities, designed for assessment and evaluation of
emergency plans and capabilities. “Drill” is defined as an activity that tests a single
procedural operation (e.g., a test of initiating a cell phone alert system or a test of
campus security personnel conducting a campus lockdown). “Exercise” is defined as a
test involving coordination of efforts (e.g., a test of the coordination of campus
administrators who oversee key units and first responders, including police, firefighters,
and emergency medical technicians). They must complete both as part of the
requirement to conduct a test.
Recommendation 11.2: Conduct an exercise (tabletop, functional or full scale/live
exercise) including at least one representative from each of the key units on campus to
test the UCONN emergency response and evacuation procedures on an annual basis.
The key units include, but are not limited to: UCPD, Housing, Dean of Students, External
Relations, Facilities Management, Risk Management, Environmental Health & Safety,
Information Technology, Human Resources, and Academic Affairs.
Recommendation 11.3: Invite the local police department, fire department and emergency
medical services department to participate in the exercise (required). If any of these
departments do not attend the exercise, document your efforts to invite them to
participate in the after action report.
Recommendation 11.4: Conduct a drill in conjunction with the annual exercise.
Recommendation 11.5: Develop a plan to publicize the emergency response and
evacuation procedures in conjunction with at least one test per calendar year. The
institution is required to publicize the date, time, whether the test was announced or
unannounced and a summary of the UCONN emergency response and evacuation
procedures. This information must be publicized throughout the UCONN community.
Recommendation 11.6: Maintain a list of all “tests” conducted by the institution starting
in 2009. This should include all drills and exercises. Minimally, the list should
include, date, time, location, whether it was announced or unannounced, and a brief
description of the drill or exercise. The list should be maintained by the Clery
Compliance Officer and should be filed in the annual compliance file.
Recommendation 11.7: Address emergency response and evacuation on a campus-wide
scale following both portions of the annual “Clery” test. “Campus-wide” scale means
that exercise must address your plan for evacuating all of your campus buildings.
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Section XII: Fire Safety Report and Fire Log
The institution has published the Annual Security Report and the Fire Safety Report as
one document, which is an acceptable practice. If they are published together, the
institution is required to call the document the Annual Security and Fire Safety Report,
but it was called the "United States Crime Awareness and Security Act" which is not in
compliance with this requirement.
UCONN provided a general description of the fire safety systems in the Report, but that
general description does not meet the requirements of the law. The institution is required
to list each residential facility and to provide a description of each fire safety system. The
fire safety systems in the Celerone Apartments were not included and need to be added to
the 2012 report.
UCONN provided some general fire statistics for the 2011 Annual Security and Fire
Safety Report, but those general statistics do not meet the requirements of the law. The
institution is required to list each residential facility (include the Celerone Apartments)
and publish specific fire statistics for each facility.
Currently, UCONN is maintaining a fire log that includes all fires. The fire log contains
four categories, including Date, Nature of Fire, Time and Location. The log needs to be
revised to include: Date Reported, Nature of Fire, Date and Time Occurred and Location.
There were several other missing policy statements in the Fire Safety Report and they
were outlined in the previously submitted Report that assessed the contents of the Annual
Security and Fire Safety Report.
Recommendation12.1: Change the name of the report to the Annual Security and Fire
Safety Report.
Recommendation 12.2: Develop a Fire Statistics chart that meets all of the requirements
of the law. List each residential facility by name and address.
Recommendation 12.3: The Annual Security and Fire Safety Report should describe the
fire safety system in each of your on-campus student housing facilities.
Recommendation 12.4: Revise the Fire Log to include the categories of date reported
and the date and time occurred.
Section XIII: Missing Persons
The missing person section of the Annual Security Report was missing only one "missing
person" policy statement, which involves notifying local law enforcement within 24
hours when the institution determines that a student is missing. The institution is
obligated to actively offer an opportunity for all students living in residential facilities to
provide a missing person contact to the institution at least once a year.
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Recommendation 13.1: Notify the residential students of the option to provide the
institution with a Missing Person Contact on an annual basis regardless of whether they
chose to register a contact the previous year, as required by law.
Section XIV: Records Retention
It appears that most records relating to the Clery Act/HEOA compliance were being
maintained for seven years, but the institution needs to ensure that all records are being
maintained as required.
Recommendation 14.1: Maintain all records pertaining to the Clery Act/HEOA
security/safety provisions for seven (7) years. Develop an institutional records retention
policy regarding all of the documents that should be maintained on file for all offices
managing/ maintaining Clery Act records.
Section XV: Reported Statistics (Charts)
The Forcible Sexual Assault category in the crime statistics chart should be changed to
Forcible Sex Offenses.
The Non Forcible Sexual Assault category in the crime statistics chart should be changed
to Non Forcible Sex Offenses.
The Hate Crime statistics documentation from 2010 showed that Captain Averna had
eight hate crimes documented, but only six were reported in the annual security report
statistics. The Clery Act requires the institution to conduct an investigation regarding any
incidents that could be bias related. The UCPD did not complete an investigation
regarding the eight incidents that were originally identified by Captain Averna.
Recommendation 15.1: Conduct an investigation and document the results of the
investigation for any incident that is potentially bias related.
Section XVI: Audit of UCONN PD Criminal Incident Reports
Captain Rhoda Averna, Lieutenant Magdalena Vargas and D. Stafford & Associates staff
Lindi Swope and Deb Pettit reviewed all of the University of Connecticut Police
Department (UCONN PD) incident reports involving reported Clery reportable criminal
incidents and all larceny and simple assault reports for 2010. This review involved
reading between 300-400 reports to verify the facts and properly classify and count the
incidents using Uniformed Crime Reporting (UCR) definitions and guidelines.
Kim Hill (Assistant Director of Community Standards), Cathy Cocks (Director of
Community Standards), Elsie Gonzalez (Assistant Director of Residence Education), and
D. Stafford & Associates staff Lindi Swope and Dolores Stafford also reviewed more
than 700 judicial referral records for all violations, including liquor, drug and weapons.
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The records regarding referrals were reviewed in the Community Standards Office and
recommendations regarding those records will be listed in Section XVII of this report.
This information about the crime statistics assumes that all of the required reports were
pulled for us to complete the review.
The original statistics for 2010 were reported as:
On Campus Non Campus Public Residential
Property
Murder/Non-Negligent
Manslaughter 0 0 1 0
Negligent Manslaughter 0 0 0 0
Forcible Sex Offenses 9 0 1 8
Non Forcible Sex Off 0 0 0 0
Robbery 0 0 3 0
Aggravated Assault 0 0 2 0
Burglary 23 0 0 16
Motor Vehicle Theft 0 0 1 0
Arson 4 0 0 4
Larceny 0 0 0 0
Liquor Law Arrests 0 0 57 0
Drug Law Arrests 47 0 107 42
Illegal Weapons Arrests 0 0 9 0
Liquor Law Referrals 714 0 75 686
Drug Law Referrals 3 0 0 2
Illegal Weapons Referrals 0 0 1 0
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The statistics for 2010 should have been reported as:
On Campus Non Campus Public Residential
Property
Murder/Non-Negligent
Manslaughter 0 0 0 (-1) 0
Negligent Manslaughter 0 0 0 0
Forcible Sex Offenses 12 (+3) 0 0 (-1) 11 (+3)
Non Forcible Sex Off 0 0 0 0
Robbery 2 (+2) 0 0 (-3) 0
Aggravated Assault 3 (+3) 0 0 (-2) 0
Burglary 26 (+3) 0 0 15 (-1)
Motor Vehicle Theft 1 (+1) 0 0 (-1) 0
Arson 5 (+1) 0 0 4
Liquor Law Arrests 47 (+47) 0 3 (-54) 0
Drug Law Arrests 135 (+88) 0 17 (-90) 40 (-2)
Illegal Weapons Arrests 7 (+7) 0 0 (-9) 0
Liquor Law Referrals 575 (-139) 1 (+1) 0 (-75) 574 (-112)
Drug Law Referrals 88 (+85) 0 0 63 (+61)
Illegal Weapons Referrals 0 0 0 (-1) 0
** Number with a plus (+) or minus (-) sign is the difference between the statistics that were originally
reported and the statistics as they should have been reported based on the what was found during the audit.
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The current process for reviewing reports and collecting information for the crime
statistics is as follows: Captain Averna goes through the records system and conducts a
search on all Clery reportable categories. She reviews the arrest log for drug, liquor and
weapons. The LEAS system does not consider a citation as an arrest, so Captain Averna
looks up the citations to count them as arrests.
For drug, liquor and weapons violations--the officer can write a report and refer the
report to the Office of Community Standards. They also have a system they call the
"buck slip" where an officer can document an incident and refer it to the Office of
Community Standards without writing an incident report in the LEAS system. They
recently developed a new buck slip form that captures additional information including
the CAD number. If an officer completes an agency referral, the officer may not write a
report for several days or the report may not get approved in a timely manner. Lt. Vargas
periodically (at least once a month) runs a report that captures all of the disposition codes
under "agency referrals" and she sends that report to the Office of Community Standards.
The current system of UCPD staff sending referrals to OCS "at least once a month" is
causing significant challenges in the student conduct process. there are times where
students are being charged with violations of the code of conduct weeks after the incident
occurred because of the delay in OCS receiving the reports from UCPD. There are times
that OCS receives an initial report within a day or so from the residence hall staff and
they move forward and process the case. They then receive a report about the same case
from OCPD weeks later, and the PD report often has additional important details that
were not known immediately to OCS and sometimes, the conduct process has already
been concluded and the sanctions have been issued to the student.
Recommendation 16.1: Develop a more timely system for distribution of reports
involving student violations of the law or violations of the code of conduct to the Office
of Community Standards to allow them to process cases in a more timely and thorough
manner.
There are some common practices that are delaying the completion of reports and the
forwarding of that information to the Office of Community Standards. Officers do not
always write all of their reports before leaving the shift for the day. Sometimes there is a
delay in the reports being approved. The chain of command for approving a report is:
Sergeant, Lieutenant, Captain. The disposition codes are not always being entered
correctly--for example, the narrative of the report indicates that the incident was referred
to the Office of Community Standards but the disposition says that case is closed. The
department should educate the officers and supervisors who review reports on the correct
usage of the disposition codes.
Recommendation 16.2: Review the current practices for writing reports for liquor, drug
and weapons violations. There are questions the UCPD administration needs to ask to
assess whether changes need to be made in the practice of documenting incidents. Is the
buck slip process effective? Failing to put all incidents in LEAS, even the incidents that
result in a referral to the Office of Community Standards, then means that information is
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not searchable like the rest of the reports. Why does a different standards exist? Is there a
good reason?
The University of Connecticut Police Department currently uses LEAS (Law Enforcement
Administrative System) report management system. This system is difficult to query
report information to collect data for Clery compliance work. Listed below are some of
the specific drawbacks of this system.
Report Module
The report functions are not flexible to:
Create reports to track Clery crime
Create a comprehensive audit trail
Search by different values other than date and time
Citation Module
It doesn’t allow searches by the charges
Citation Search function doesn’t work
There isn’t an area to search by incident number
There is no link between the citation module CAD remarks and incident modules,
the user must go to each area independently.
The system is not currently capable of counting the Clery statistics. The current system of
counting Clery statistics is a combination of the system and the user.
We found various errors in what was originally reported in the 2010 statistics such as:
LARCENY- Ex. Case #10-3786: A CAD entry was completed, no report was
done to collect all of the elements of the crime to ascertain whether or not the
report may meet the criteria of a burglary. The CAD entry only states that the
victim reported their cell phone stolen, however no details of the nature of the
theft (location).
LARCENY- Ex. Case #10-7529: The theft of an instrument from a locker within
a storage closet. The report does not state whether or not the storage room is
locked or unlocked which is necessary information to properly classify the
incident from a UCR perspective.
BURGLARY- Ex. Case 10-9736: This incident should have been counted as two
burglary offenses since it occurred in a residential suite where there was unlawful
entry of the suite area AND the bedroom, thus both need to be counted.
LIQUOR LAW ARRESTS--Challenges:
o Liquor law infractions do not get police reports generated in LEAS, but do
get a CAD entry.
o Liquor Arrests (Infractions) (Administrative Disposition 03)-- An
infraction is issued to the subject(s). The officer types a brief summary of
events on the back of the infraction. In LEAS, a CAD entry is generated.
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The infraction is entered into the Citation module and other involved
parties are entered into the Name Field of the CAD entry. No LEAS police
report is generated, the information captured on the back of the infraction
is considered the report. *The process for any other arrests in combination
with Liquor would result in a LEAS report.
o Liquor Referral (Administrative Disposition 02)--A CAD Entry is
generated, no LEAS police report generated when no enforcement needs
exist. (These are potential judicial referrals).
o Ex 10-18919: This CAD entry only includes names and has no typed
information regarding the circumstances. Lt. Vargas stated this case is
most likely involving students over 21 and therefore no further
information was provided. It is recommended that information is typed
into the CAD entry so an auditor would understand this entry.
o Referrals & Arrests (Infractions) (Administrative Disposition 01)-- A
written report is generated based on the complexity of the incident. It is
possible that infractions and referrals may exist in these reports.
o Assessment process by PD for Liquor Referrals: There is a Case
Disposition box which must be checked on every report before they are
fully reviewed. Sergeants, Lieutenants & Captains are all a part of this
review process. The Case Disposition is a part of the decision making
process to forward reports to the Office of Community Standards as well
as assessing the “Call type” aka crime classification and if it is Clery
reportable, it is referred. The Case Management Module is what alerts the
assessment process for the review and when is finished, it is marked
“Checked” in the system. The “Agency Referral” box is checked which
triggers UCPD to send the reports to Office of Community Standards.
LOCAL LAW ENFORCEMENT STATISTICS - Connecticut State police
statistics were originally not counted due to a misunderstanding of Clery
Geographic requirements. There were two countable burglary incidents reported
to CSP which should have been counted. 10609190 & 1074828.
ASSAULT- Generally, injuries suffered from assaults were not usually described
and when persons went to the hospital, no one followed up on the extent of the
injuries.
o Ex. Case 10-25689: A victim was punched by several people. He was
found bleeding from face and head and went to hospital. No follow up on
the injuries. The follow-up is necessary in these cases to determine
whether a case should be counted as aggravated assault or simple assault.
o Ex. Case 10-9449: A victim was attacked by 10 people hit in head with
beer bottle and found with deep laceration to leg. No follow up on leg
injury. We changed this from simple to aggravated assault.
o Ex. Case 10- 9183: An incident was classified as a simple assault that
involved a knife being used to cut victim. We changed this from simple to
aggravated assault.
UNFOUNDED CASES- The PD does not currently have a way to check for
unfounded cases. They manually looked up the sexual assault cases and they
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found that Case 10-13054 was unfounded. They did not look up any of the other
cases so there may be other incidents that we reviewed that were unfounded.
DATE OF REPORT- The date reported is sometimes the date the officer puts
the report into the computer or date the incident occurred rather than the day the
police take the report. Ex. SA 10-4481 had 3/2/10 and is 3/1/10 and SA10-9492
has 4/24/10 and is actually 4/30/10. A motor vehicle theft was reported with a
date of 11/10/2010, which is the date it occurred when it was reported to police on
11/11/2010.
ARSON-Ex. Case 10-10261. Fire occurred on 5/5/10 outside of the Celeron
dumpster. The Mansfield Fire Department responded. CUPD did not get the
investigative report to determine whether or not the incident should be counted as
arson. UCPD needs to verify that the fire department investigates any fire that is
not immediately known to be accidental or the UCPD needs to conduct the
investigation. The institution is required by the Clery Act to conduct an
investigation, so if the fire department does not do it, the institution must have a
process in place to conduct the investigation.
Recommendation 16.3: UCPD needs to be able to assess whether or not subjects
involved are current students. There needs to be a system in place to confirm
involved parties status especially for liquor, drug and weapon law offenses.
Currently, LEAS does not capture this information.
Combining Cases: There is a pattern regarding officers combining cases that should not
be combined and separating cases that should be considered one case.
Ex. Case 10-4351: Male in a residence hall at 0513 hours yelling on phone told to
quiet down or be arrested. Police left and at 0614 hours encounter same subject
outside residence hall yelling so they arrest him for breach of peace and
possession of drugs. This should have been written as two separate cases due to
the separation in time and place. Ex Cases 10-9025 and 10-9027: There was no
separation in time or place. The officer arrested one person for drugs in 10-9025
and one person for alcohol and one for drugs in 10-9027. These two cases could
have been written as the same report.
Ex. Case 10-26813: In a traffic stop for drugs, officers found a UCONN ID card
not belonging to anyone in the car. The officer later goes to room of the person
the ID belongs to, searches the room and finds roach and wooden box with
Marijuana residue. This should have been written as two cases due to separation
in time and place.
Recommendation 16.4: Train the officers in when to complete a separate report and when
to combine reports. They need to understand that the UCR concept regarding counting
crimes revolves around a separation in time and place.
Errors in the reported location of the incident (which causes inaccuracies in reporting the
statistics in one of the 4 required geographical locations):
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Officers often times use the Police Department's building address when taking
reports in the office instead of using the location where the incident occurred.
This creates incorrect geographic statistics for Clery reporting requirements.
Incident reports need to reflect the specific building location of an incident. For
example, North Campus is sometimes used on reports as the location, but North
Campus contains approximately 12 different dorms each with a specific dorm
name (EX. 10-21702).
All non campus locations are not currently being captured (ex. Lee Farm in
Coventry, CT) and off site facility usage assessments need to be made to know if
these locations may or may not be Clery reportable.
Incident locations need to be specified, often times incidents occurred outside a
building but the location was listed having occurred in the building.
All weapons violations were counted as public property and they were all on
campus.
In general, the location of incidents the officers use is a street address near an
incident or address of an entire residential housing unit. These locations need to
have building names and more specific locations so the on-campus, off campus,
and residential areas can be accurately recorded. Often times the officers will
record an incident as a building or residential address when the offense is really
occurring outside of the building.
Recommendation 16.5: Do not use the Police Department address as the location of an
incident unless the crime occurs in the Police Department (not likely).
Recommendation 16.6: Do not use a general location of North Campus when the incident
occurs in a specific building. The building name and/or address should be used whenever
possible.
Recommendation 16.7: Do not use the name or address of the closest building as the
location for an incident report for incidents that occur outside. If an incident occurs on a
street, use the street name. If the incident occurs in an outside area that has a name, use
that name. If an incident occurs in an outside area that does not have a name, indicate that
it happened outside and pick a landmark to provide a sense of where it occurred.
The UCPD did not have an audit trial that was adequate and that meets all of the
requirements outlined by the Department of Education Auditors (as currently being
requested when the Department of Education notifies institutions of a scheduled audit)
for maintaining detailed information about the crime statistics being counted for Clery
Act purposes. We created a 2010 audit trail that identifies all of the required information
for each crime that needs to be reported. That system was used when we conducted the
audit of 2010 Incident Reports.
Recommendation 16.8: This system should be continued in the future to assist with
auditing of records and verifying the crime statistics at the end of each year.
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An excel spreadsheet exists from the Registrar’s Office and is often times inaccurate
which makes it challenging for the UCPD to determine whether or not they are dealing
with students or non students. The UCPD officers need to verify and document the ages
of the students who are listed in the incident reports, this is particularly important in cases
involving liquor violations, as Captain Averna needs to determine whether or not those
incidents should be documented as potential liquor law referrals.
Recommendation 16.9: Require the officers to list the date of birth of any subject
involved in an incident report involving alcohol (at a minimum).
Recommendation 16.10: There are several issues that need to be addressed through
additional training and education of the officers and supervisors in the department:
-The officers need to gather more information for incident reports classified under
the larceny and burglary categories. They need to ask questions such as: Was the
room/facility locked? Who secured the room/building, and when (date and time)?
When is the last time the victim saw the property? When did victim notice the
property missing?
-The officers need to describe any injuries that a person received during an assault
and if there were any weapons used during the assault.
-The officers need to clearly indicate if a weapon is used in an assault. If a
weapon was not used, they should indicate any and all injuries in the incident
report.
-In incident reports that involve an arrest, the officers need to summarize in the
narrative who was arrested and for what specific offenses.
-The officers need to identify the specific hundred block or landmark when
reporting incidents that occur on public streets that run through or border the
campus.
The institution should develop a consistent practice and document that practice in the
Clery Compliance SOP regarding generally, how Clery crimes are counted.
Recommendation (for SOP language) 16.11: Clery crimes are typically counted where
the crime or violation occurred or was witnessed by the officer, except in stances of
traffic stops, as described below.
The institution should develop a consistent practice and document that practice in the
Clery Compliance SOP regarding how Clery crimes are counted involving traffic stops
(Ex. Case 10-3657). If the officer observes a traffic violation, and a subsequent Clery
violation is identified once the vehicle is stopped, is the crime being counted where the
traffic violation occurred or where the traffic stop was made by the officer?
Recommendation (for SOP language) 16.12: If the officer observes traffic violation on a
public street within the core campus (i.e. “on campus” property) and follows the person
outside the core campus (i.e. off campus) and he/she then identifies a drug law violation,
the incident should be counted where the car was stopped and the Clery violation was
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observed. Therefore, this incident would be an off campus drug law violation, which
would not be counted in your Clery statistics. In the converse, if the officer observes a
traffic violation outside the core campus, (i.e. off campus) and follows the person on
campus to make the traffic stop (i.e. within the core campus) and identifies a drug law
violation, the Clery crime should be counted as an on campus or public property crime
(depending on whether it is a public street or a University owned street).
Recommendation 16.13: If the officer observes a liquor violation on a public street within
the core campus (i.e. “on campus” property) and follows the person outside the core
campus (i.e. off campus) the incident should be counted where it occurred. In the
converse, if the officer observes the crime outside the core campus, i.e. off campus and
follows the person to an on campus location i.e. within the core campus, the incident
should be counted as having occurred at the off campus location where it occurred.
Appendix #7--Excel spreadsheet with a ‘sheet’ for each crime category that includes the
incidents that were verified in each category during the audit. (Saved as: Clery Chart
UCONN 2009-FINAL)
Appendix #8--Cover sheet for Part 1 Crimes
Appendix #9--Cover sheet for Liquor, Drug and Weapons Violations
Section XVI: Audit of the Office of Community Standards Records and Processes
Kim Hill (Assistant Director of Community Standards), Cathy Cocks (Director of
Community Standards), Elsie Gonzalez (Assistant Director of Residence Education), and
D. Stafford & Associates staff Lindi Swope and Dolores Stafford also reviewed more
than 700 judicial referral records for all violations, including liquor, drug and weapons.
The statistics for referrals for liquor violations and drug law violations were inaccurately
reported.
UCPD used the information provided by the Office of Community Standards (OCS) to
report the "referral" statistics for the institution. The original statistics provided by OCS
and reported by UCPD were:
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On Campus Non Campus Public Residential
Property
Liquor Law Referrals 714 0 75 686
Drug Law Referrals 3 0 0 2
Illegal Weapons Referrals 0 0 1 0
In reviewing the 700+ judicial referral records for all violations, including liquor, drug
and weapons, we found that there were a significant number of referrals for liquor and
drug violations that were not reported correctly. The statistics should have been counted
as follows (these numbers are also listed in the crime statistics chart in Section XVI):
On Campus Non Campus Public Residential
Property
Liquor Law Referrals 575 (-139) 1 (+1) 0 (-75) 574 (-112)
Drug Law Referrals 88 (+85) 0 0 63 (+61)
Illegal Weapons Referrals 0 0 0 (-1) 0
There were several practices that were in place in 2010 that affected the errors in the
referrals statistics that were reported to UCPD by OCS. These practices included:
OCS reported all incidents of intoxication (174 cases) to UCPD because they
believed that those incidents were violations of the law and countable under the
Clery Act. This is the reason for the majority of cases that were over-reported by
OCS.
OCS was told by UCPD that if UCPD officers responded to an incident and sent a
report to OCS, OCS should not report those referrals back to UCPD. The
assumption was that if UCPD was present on the scene, they were counting that
incident as a referral. This appears to be the reason for OCS under-reporting the
drug referrals to the UCPD.
Currently (as of 2011), the system between the two departments is as follows: UCPD is
counting the arrests for drug, weapon and liquor law violations from the police
department records. For the referrals, the Office of Community Standards is
automatically counting and reporting back to UCPD all non arrests (all referrals for
current students) for liquor, drug and weapon offenses where the student was charged
with a violation of the law, as well as any other Clery crime that is reported to OCS by
anyone other than UCPD. OCS also sends data regarding the arrests that was reported to
them back to UCPD for verification purposes.
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As we were completing the audit of the disciplinary records, we identified various
problems with the current systems and processes. Listed below are some general
problems that were identified and recommendations to improve and enhance the current
systems that are in place:
We assisted the UCPD in conducting as assessment of the UCR definitions of
drug law violations, liquor law violations, and weapons law violations. Lt Vargas
completed an assessment of the state laws and local ordinances that fall under
those three UCR definitions. The final assessment should be shared with the
Office of Community Standards to educate them about the specific violations of
state and local law that are Clery countable so they can conduct a similar
assessment involving the drug, liquor and weapons violations in the Student Code
of Conduct.
In 2010, in general, the incident categories that are being used by OCS do not
allow for the staff in that office to determine if the incident should have been
counted as a Clery Reportable offense. For example, they used categories like
Liquor Violation, but the types of incidents they put into these categories include
violations of law and violations of policy (that are not violations of law).
Currently, OCS has a means to identify an incident as a Clery reportable
violation using a dropdown menu in the PAVE.
In cases where a student is referred for multiple violations as part of the same incident,
specifically in the areas of drugs, alcohol, and weapons violations, the incident should be
entered into PAVE using the most serious offense. For example, if the individual violates
a liquor law (by possessing a six pack of beer) and a drug law (by possessing 16 oz of
marijuana)—it should be captured in the database as the most serious offense, i.e. the
drug violation. Ex. Case 10-28681--this case should have been counted as a referral for
(Virgilio) drugs and (Blackman) for liquor.
Recommendation 17.1: Use the UCR hierarchy in capturing incidents in PAVE to allow
the highest violation (crime) to be captured for Clery reporting purposes.
In addition, there are incidents where the student was referred for two violations and one
is a Clery countable violation and the other isn’t. For example, a person who is under 21
is referred for DUI and Possession of Alcohol. List this in the system as a possession
violations, because that violation should be counted in the Clery Act statistics and DUI is
not a reportable category.
Recommendation 17.2: The Clery countable category should be the one entered into the
database, so the statistic can be identified and counted.
There were instances of liquor law reports being classified by UCPD as non Clery
reportable offenses (Disorderly Conduct (10-24906), Vandalism (10-23682) which
involved the presence of alcohol, but were not captured by UCPD as potential referrals
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University of Connecticut Clery Audit Draft Report 29
due to the classification and the process of running reports in LEAS to review only Clery
crime code call types.
Cases 10-28675, 10-29972 and 10-24160 are in LEAS as a Narcotics offenses but do not
appear on the LEAS Case Incident Report based on Call Type which Captain Varga uses
as her audit trail. We are not sure why they did not show up on the report that generated
that was supposed to identify all of the narcotics cases. This type of problem in the
system could impact the Clery statistics, if she is running a report to try to identify all
narcotics cases, and some of them do not show up on the report. This potential system
error should be investigated.
The UCPD staff is often times responding to calls involving liquor, drug or other
violations in the residence halls, and they are not consistently writing a report about the
incident or they have documented some of the people involved, but not all of them. Ex.
Case 10-2976-- this case involved 9 students and OCS adjudicated all 9 students. The
UCPD incident report only named 3 students ( Benn, Woodruff & Seiwertsen). The other
6 names were given to the RA to be documented in their reporting process. It is
recommended that UCPD document all involved parties in their incident report.
Currently, officers only CAD entries are being generated for liquor law offenses
involving arrests and referrals combined. Only CAD entries are generated for single
incidents of arrests or single incidents of referrals. Using the current LEAS system this
makes it highly probable that potential arrests and referrals are not being counted due to
LEAS reporting deficiencies.
Recommendation 17.3: The officers need to be encouraged to write a thorough report any
time they respond to an incident involving a crime or incident that could be a referral to
OCS.
OCS staff should review the current locations that are available in PAVE to ensure that
they can properly identify incidents that occur on campus (within the core campus map),
in non-campus locations, and on public property--which are all Clery reportable
geographic locations. They also need to be able to log those cases that occur off campus
and thus, are not Clery reportable.
Overall, in some cases, OCS originally over counted the statistics, because they counted
some crimes that are not Clery reportable, such as DUI or Intoxication. In some cases,
they under-reported because of guidance they were given by the previous administration
of UCPD about what to report back to UCPD and what they would count using their own
records. Some mistakes were caused by inadvertent human error, and some were due to a
lack of complete understanding of the requirements of the Clery Act reporting guidelines.
The staff in the Student Conduct Office was actively engaged in the audit process and
they were helpful and receptive throughout our visit. We were impressed with their desire
to learn how to improve the reporting process for the future.
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University of Connecticut Clery Audit Draft Report 30
Recommendation 17.4: The Office of Community Standards needs to send all records
regarding reported crimes to UCPD each month, to allow UCPD staff to compare that
information to their records and capture the statistics for any criminal incidents that were
not reported directly to the PD. This will assist the staff at UCPD in keeping the crime
log updated on a regular basis, rather than adding all of that information to the log at the
end of the year.
Recommendation 17.5: The Office of Community Standards should continue to send a
spreadsheet to UCPD at the end of the year to allow them to cross-reference the
information on their audit trail to the information provided by OCS, to ensure that all
cases UCPD sent to OCS are accounted for and that there are no errors in counting the
arrests versus the referrals. The spreadsheet should contain, at a minimum: the violation,
the UCPD case number, the student's name, the location of the incident, and the date of
the incident.
XVIII. Overall Recommendations:
Recommendation 18.1: The institution should initiate a Clery/HEOA Committee that
includes, at a minimum (if you have these units/departments): UCPD, Compliance and
Internal Audit, Office of Community Standards, Student Activities, Residence Life and
Housing, Environmental Health and Safety, and the Office of the General Counsel.
Recommendation 18.2: The following offices, at a minimum, should be responsible for
reviewing and signing off on the accuracy of the policy statements and other information
contained in the Annual Security/Fire Safety Report prior to publication each year:
a. UC Police Department
b. Compliance and Internal Audit
c. Office of Community Standards
d. Risk Management
e. The Women’s Center/Sexual Assault Advocate
f. The Office of the General Counsel
g. UCONN Fire Department
Recommendation 18.3: Maintain an annual compliance file with all records pertaining to
each compliance cycle.
Recommended