Clery Compliance Steering Committee

The Clery Compliance Steering Committee (CCSC) is comprised of identified stakeholders to enhance university safety. This is accomplished through comprehensive oversight, review, revision, and implementation of all policies and procedures relating to the Clery Act (see Background below). The CCSC:

• Facilitates cross-university cooperation in all efforts to comply with the Clery Act
• Promotes education and training relating to Clery Act compliance
• Enhances awareness of policies and programs that support a secure university environment through the development and distribution of its Annual Security and Fire Safety Report and through its Drug-Free Schools Act Information

All CCSC members are responsible for assisting in the creation, development, and collection of data that supports the requirements of the Clery Act. Members will provide records, documentation, and proof on a regular and ongoing basis to the co-chairs. Documents and proof will include but not be limited to regular reports and logs of:

• Any property acquisition or sale by the university
• Any changes in venue for classes, especially in the separate campuses
• Any locations where events were held
• Any locations where Study Abroad and off-campus locations of study, athletic events, academic events, etc. were held
• Any Campus Security Authorities (CSA) training records
• Any other documents requested by the co-chairs that would assist in the completion of the Annual Security and Fire Safety Report, the Daily Crime and Fire Log, CSA training, or other documents required by the Clery Act or its successors

The Clery Act 

The Jeanne Clery Disclosure of Campus Security Policy and Crime Statistics Act (Clery Act) is the landmark federal law, originally known as the Campus Security Act, that requires colleges and universities across the United States to disclose information about crime on and around their campuses. The law is tied to an institution’s participation in Federal Student Financial Aid programs and it applies to most institutions of higher education, both public and private. The Clery Act is enforced by the United States Department of Education. Possible consequences for an institution’s non-compliance with the Clery Act include:

• Suspension or limiting of the institution’s Title IV funding
• Department of Education may issue a civil fine
• Reputational loss due to negative media attention
• Failure to comply with the Clery Act can be used in various litigation matters

The Department of Education recommends that institutions establish Clery Advisory Committees to ensure full compliance with the Clery Act. Western Washington University hereby establishes the Clery Compliance Steering Committee to direct Western’s efforts regarding Clery-related security issues facing the university.

Membership

Membership consists of individuals who by nature of their job title, responsibilities, and involvement in activities that support Western’s compliance with the Clery Act. These members are (1) Compliance Owners and (2) Compliance Partners. The roles of Compliance Owners and Compliance Partners are defined in Western’s University Compliance Program.

The Compliance Owners are designed as co-chairs of this committee. The Compliance Partners are individuals who are identified by the co-chairs and appointed by the Vice President for Business and Financial Affairs and the Vice President for Enrollment and Student Services

Compliance Owners

Chief of Police 
Executive Director of Student Life 

Compliance Partners

Clery Compliance Coordinator, University Police Department 
Program Assistant, Clery Compliance, University Police Department 
Compliance and HIPAA Officer
Director, Prevention and Wellness
Director, University Residences
Director, Athletics
Director, Business Services/Chief Procurement Officer
Travel Program Specialist, Business Services
Assistant Registrar, Enrollment Management
Director, University Communications and Marketing
Vice Provost, Outreach and Continuing Education
Employment Relations Specialist, Human Resources
Executive Director, Office of Civil Rights and Title IX Compliance
Assistant Director-Asset Management, Facilities Development & Operations 
Assistant Attorney General (ex officio)
Staffed by the University Police Department 

Meeting Frequency and Length

The CCSC will meet as needed, with a minimum of once per quarter. The meeting date, time, and location will be arranged by the co-chairs with an emphasis on finding a date, time, and location convenient for a majority of the membership.

Attendance

If a member is aware that they will not be able to attend a meeting, notice should be provided to the co-chairs as soon as possible. Qualified alternates, appointed by members, may represent members.

Meeting Agendas/Minutes

Agendas are set by the co-chairs, utilizing recommendations from the membership. Minutes of the previous meeting may be accepted by acclimation. Meeting minutes will be distributed to the membership within 30 days of the meeting. Corrections and/or edits may be recommended by email prior to acceptance at the next meeting. Meeting minutes will be kept in accordance with Western’s retention guidelines.

Subcommittees

The CCSC will accomplish its work largely through the use of subcommittees. Specific subcommittees may be constituted by the committee to address areas of compliance with the Clery Act that do not require the convening of the full CCSC. The co-chairs, work, schedule, reporting mechanisms, and duration of subcommittees should be identified in the meeting minutes.

Assistant Attorney General Participation

An Assistant Attorney General will provide legal advice to the CCSC but will not be a voting member. The co-chairs may make recommendations to the vice presidents for appointments. Additional committee members may be appointed at the discretion of either vice president. The maximum membership is 25.

Annual Report

The CCSC co-chairs shall submit an annual report to the Vice President for Business and Financial Affairs and the Vice President of Enrollment and Student Services, who will share the items, as appropriate, with the other vice presidents and the President.

Charter Review

The Charter shall be reviewed every even year beginning in 2022.

For more information about the Clery Compliance Steering Committee, please email either of the committee co-chairs by clicking on one of their names in the table above.