Clery Act Compliance – Policy, Guidance, & FAQ
Official Policy – Clery Act Compliance
Randolph College is committed to maintaining a safe and secure environment for the entire campus community. In compliance with The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (“Clery Act”), the College maintains information about campus security policies, crime statistics and mandatory reporting obligations by Campus Security Authorities on this site.
Frequently Asked Questions
- What is the Clery Act?
- What is a Campus Security Authority (CSA) and how do I know if I am one?
- What does being a CSA mean?
- What do I need to report?
- What are the Clery Act incidents?
- What is our Clery Act geography?
- How do I make a report?
- Do I need to witness the criminal incident firsthand?
- When do I need to report the criminal incident to the Director of Campus Safety/Clery Compliance Officer?
- What if I’m not sure if a crime has actually occurred?
- What if the information I have is second or third hand – do I still need to report?
- What is “good faith”?
- If I make a report, does this mean that a Police investigation will be initiated?
- If a student reported something to me in confidence, do I still need to report the incident for Clery Act purposes?
- Is this the same as the reporting of sexual assault/harassment that I must do under the Policy Prohibiting Title IX Sexual Harassment and Gender-Based Harassment?
- What is not the responsibility of a CSA?
- What fines and/or sanctions could Randolph College face if I fail to report an incident?
- What sanctions could I face if I fail to make a report?
What is the Clery Act?
The “Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act” is a federal law that requires institutions of higher education in the United States to disclose campus security information (including crime statistics and information about safety-related policies). It was first enacted by Congress in 1990 and amended several times since. Jeanne Clery was a student who was murdered and sexually assaulted in her residence hall room by another student she didn’t know. Her school hadn’t informed students about 38 violent crimes on campus in the prior three years. Jeanne’s parents advocated for the new law.
What is a Campus Security Authority (CSA) and how do I know if I am one?
While not defined in statute, regulations provide that CSAs include:
- Campus Police or security department personnel.
- Individuals or organizations identified in institutional security policies.
- Individuals with security-related responsibilities, or an official “who has significant responsibility for student and campus activities”.
The Director of Campus Safety/Clery Compliance Officer regularly reviews employees who are designated as CSAs to ensure compliance with the regulations. Annually, CSAs are notified of their status as a CSA and training for fulfilling their obligations as a CSA is provided.
What does being a CSA mean?
It means you have certain reporting obligations, described in these FAQs.
What do I need to report?
You need to report certain criminal activity known as “Clery Act crimes” that you become aware of and that occur on college property designated as our “Clery Act geography.” The reporting requirement is triggered by the location where the incident occurred. It only applies to criminal incidents occurring in Randolph College’s Clery Act geography.
What are the Clery Act incidents?
Clery Act incidents include murder, manslaughter, robbery, burglary, arson, sex offenses including rape, fondling, statutory rape or incest, aggravated assault, motor vehicle theft, drug abuse violence, liquor law violations, weapons possession violations, Violence Against Women Act offenses including dating violence, domestic violence and stalking, and Hate Crimes. Definitions are provided in the Clery Act Compliance Policy.
Drug abuse violations and liquor law violations that result in either an arrest or a disciplinary referral also need to be reported, but this information is most reliably collected from the Dean of Students Office, which handles disciplinary cases against students.
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What is our Clery Act geography?
Three types of property constitute our Clery Act geography:
On-Campus
Any building or property which is owned or controlled by an institution within the same reasonably contiguous geographic area and is used by the institution in direct support of, or in a manner related to, the institution’s educational purposes, including residence halls; and
Any building or property that is within or reasonably contiguous to the area identified in paragraph (1), that is owned by the institution, but controlled by another person, is frequently used by students, and supports institutional purposes (examples include food or retail vendors).
Residential Facilities
Halls on College property:
- Bell Hall
- Main Hall
- Moore Hall
- Webb Hall
- West Hall
- Wright Hall
Grosvenor Apartments
Non-Campus Building or Property
Any building or property owned or controlled by a student organization that is officially recognized by the institution; or
Any building or property owned or controlled by an institution that is used in direct support of, or in relation to, the institution’s educational purposes, is frequently used by students, and is not within the same reasonably contiguous geographic area of the institution.
*Randolph College has no off-campus student organization facilities.
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Randolph College Properties
(All Properties Located Within the City of Lynchburg, VA unless otherwise noted)
All Buildings Located at 2500 Rivermont Avenue:
- Am Sam Cabin – Student Activity
- Bell Hall – Residence Hall
- Boiler Room/Power Plant – Mechanical
- Cheatham Hall – Dining Hall
- Dell Stage – Outdoor Theatre
- Houston Chapel – Assembly
- Leggett – Academic Building
- Lipscomb Library – Library
- MAC (Michels Athletic Center) – Athletics and Dance
- Mailroom
- Maier Museum of Art – Art Museum
- Main Hall – Administrative Offices and Residence Hall
- Student Center
- Martin Science – Academic (includes offices and labs)
- Moore Hall – Academic and Residence Hall
- Nursery School (accommodates ages 3-5)
- Norfolk House – Vacant/Storage
- Observatory – Academic
- Pines House – Academic (Art)
- Presser – Academic (Music)
- Psychology – Academic (includes classrooms, labs, and offices)
- Smith Hall – Academic (includes classrooms and offices)
- Terrell Health and Counseling Center –Counseling and Health Services
- Thoresen Hall – Staff/Faculty Offices
- WildCat Stadium Fieldhouse – Athletics
- WildCat Stadium Press box – Athletics
- Webb Hall – Residence Hall
- West Hall – Residence Hall
- Wright Hall – Residence Hall
Off Campus Properties:
- 2476 Rivermont Avenue – Business Lease with Magnolia Foods
- 2480 Rivermont Avenue – Business Lease with Riverside Runners
- 2472 Rivermont Avenue – Parking lot
- 158, 162, 166A, 168A, 168, 170 and 172 Norfolk Avenue – Lots
- 22 North Princeton Circle – Lot
- 1031 Ashland Place – Lot
- 2601 Rivermont Avenue (Doyle House) – Institutional Advancement Offices
- 2615 Rivermont Avenue (Casey House) – Alumnae Offices
- 2711 Rivermont Avenue – Admission Offices
- 2715 & 2717 Rivermont Avenue – Grosvenor Apartments – Residence Hall
- 3115 Rivermont Avenue – Randolph House (President’s Residence)
- 176 Norfolk Avenue (Butler House) – Institutional Advancement Offices
- 223 Westmoreland Street – Parking lot
- Plot 22-A-74 (Wards Road) Campbell County, VA – Land
- Plot 24-2-A (Campbell Highway) Campbell County, VA – Land
- Plot 24-2-B (Campbell Highway) Campbell County, VA – Land
- Plot 135-A-12 (Route 787 Burgess Road) Amherst County, VA – Land
Public Property
All public property, including thoroughfares, streets, sidewalks, and parking facilities, is within the campus or immediately adjacent to and accessible from the campus.
The campus is surrounded by the following public streets:
- Rivermont Avenue to the south and east.
- Norfolk Avenue to the east.
- North Princeton Circle to the west.
- Quinlan Street partially to the south as it becomes a private roadway that terminates at the Maier Museum of Art, 1 Quinlan Street.
The southern-most section of the College’s property is heavily wooded to the James River.
Note: Reported crime statistics do not include crimes that occur on privately owned property or businesses on or adjacent to Randolph College property. This data is available from the Lynchburg Police Department Crime Analysis Unit, and Campbell Sheriff’s Departments.
How do I make a report?
A CSA must file a report with the Director of Campus Safety/Clery Compliance Officer when they become aware of information that indicates that a Clery Act crime occurs on campus property, adjacent to campus, or in a non-campus location. The Randolph College Campus Safety Department is designated as the official collector of crime report information for our campus.
- Contact the Randolph College Campus Safety Reception and Information Desk by phone at 434-947-8000 or in person at the Reception and Information Desk located in Main Hall.
- Identify yourself as a CSA and you need to speak to the Director of Campus Safety/Clery Compliance Officer.
- Provide a description of the incident to the Director of Campus Safety/Clery Compliance Officer. You do not need to identify the specific Clery Act crime involved. For example:
- “A student informed me that their parked car in the Bell parking lot was broken into during class yesterday.”
- “I was told that someone holding a knife robbed a student on campus and while doing it called the student a derogatory name based on his sexual orientation.”
- “I heard students talking about a possible rape that happened last night in West.”
- Provide date and time (or approximate time) of the incident.
- Provide the specific location or location to the nearest address/point possible.
You are not required to, but may elect to, provide the name of individuals involved unless it is a sex offense or a Violence Against Women Act offense, in which case you are required to provide all details of the incident and the individuals involved that you know.
Do I need to witness the criminal incident firsthand?
No. The reporting obligation arises when a CSA becomes aware of information or allegations of criminal behavior. Awareness can be either through witnessing criminal conduct or having criminal activity reported to you by a victim, bystander, or other person.
When do I need to report the criminal incident to the Director of Campus Safety/Clery Compliance Officer?
You should report the criminal incident to the authorities in a timely manner. In non-emergency situations (e.g., not an ongoing threat), CSAs must report promptly given the circumstances. For CSAs in non-campus locations, especially abroad, that may not be possible until your return to campus. Obviously, in emergency situations, contact local law enforcement wherever you may be. Do not wait for criminal charges to be brought or arrests to be made.
What if I’m not sure if a crime has actually occurred?
You should still report. It is not your job to decide whether there is enough evidence or if all the elements of a crime occurred; if you have information that reasonably appears like a Clery Act crime, report it. You should also remember that attempted crimes must be reported.
What if the information I have is second or third hand – do I still need to report?
Yes, you need to report.
The only times you do not have to report information about a Clery Act crime are…
- if you have reason to believe that the report or allegation of criminal conduct is not made in good faith or
- if you are certain that the incident has already been reported to Campus Safety.
This means, for example, if an employee tells you that a local resident, who was visiting campus, was mugged behind one of the academic buildings, you need to report that.
If a student requests an extension for their assignment because they were robbed at gun point outside their residence hall the previous evening and they were being interviewed by Campus Safety until midnight, you should check with the Director of Campus Safety/Clery Compliance Officer to make sure this is true and if not report it.
What is “good faith”?
If you have good reason to doubt the validity of the information – for example if you think someone is deliberately spreading a rumor – you could conclude that the report was not made in good faith. If you have reason to believe that information you received about an incident is not made in good faith, you do not need to report it.
Please be very cautious in deciding that an incident is not in good faith, particularly if the incident is sexual violence. There are many reasons why a report of sexual violence may sound implausible. Usually, the best approach to take if you have doubts about the validity of information about a crime is to report the matter and share your concerns with the Director of Campus Safety/Clery Compliance Officer, rather than deciding not to report.
If I make a report, does this mean that a Police investigation will be initiated?
No. Although we strongly encourage victims of any crime to report incidents and seek assistance through legal channels whenever possible, a report from a CSA will not necessarily result in a police investigation.
If a student reported something to me in confidence, do I still need to report the incident for Clery Act purposes?
Yes. All incidents which meet the criteria described above must be reported to the Director of Campus Safety/Clery Compliance Officer for statistical collection purposes.
Reports may, however, be filed without providing the name of the victim unless it is a sex offense or Violence Against Women Act offense, then a CSA must report all information that they know or have been told.
Only those CSAs who are designated confidential resources for students, such as professional mental health counselor or medical physician, are exempt from the requirement to report, and only if they learn of the Clery Act incident while acting as a professional mental health counselor or pastoral counselor, respectively. If an individual designated as a confidential resource is told by an employee that they are being stalked on their way to work by a former partner, the individual must report the incident to the Director of Campus Safety/Clery Compliance Officer. If the individual designated as a confidential resource hears a student say that a picnic table in front of the Cheatham Dining Hall was set on fire, then the CSA would report the arson to the Director of Campus Safety/Clery Compliance Officer.
Is this the same as the reporting of sexual assault/harassment that I must do under the Policy Prohibiting Title IX Sexual Harassment and Gender-Based Harassment?
No, but it is related. Sexual assaults, including rape and fondling, are Clery Act crimes that you must report to the Director of Campus Safety/Clery Compliance Officer as a CSA. Under the college’s Title IX Policy, all employees (other than designated confidential resources) — are considered a “mandatory reporter.” Employees must report to the Title IX Coordinator sexual harassment against Randolph College students or employees. If you report to the Director of Campus Safety/Clery Compliance Officer an act of sexual assault as a CSA, then you have satisfied your obligation of reporting it as a form of sexual harassment to the Title IX Coordinator
What is not the responsibility of a CSA?
The CSA is not responsible for proving or deciding whether the alleged incident actually occurred—that is the job of Campus Safety and/or Law Enforcement. A CSA should not investigate or ask questions of a harmed or accused individual.
The CSA is not required to be a neighborhood monitor or to actively seek out crime information such as by reading crime blogs.
It is not the CSA’s responsibility to try and convince a victim to contact law enforcement if the victim chooses not to do so. The CSA should support the victim’s choice, and, if the victim is a Randolph College student, offer to accompany the victim to make a report to Campus Safety.
What fines and/or sanctions could Randolph College face if I fail to report an incident?
The United States Department of Education is charged with enforcing the Jeanne Clery Act and may level civil penalties against institutions of higher education of more than $69,733 per violation or may suspend them from participating in federal student financial aid programs.
What sanctions could I face if I fail to make a report?
Under the Crime Reporting Policy, CSAs who fail to report Clery Act incidents may be subject to disciplinary action under applicable personnel policies.
