DIY: 10-step guide to auditing your school’s compliance with the Clery Act

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act is a federal law that requires colleges to disclose information about crimes on campus, as well as policies to prevent and respond to crimes. Under the Clery Act, colleges that receive federal funding must report annual crime statistics, maintain a daily crime log, and produce an annual report detailing security policies. The Department of Education is in charge of enforcing the Clery Act and ensuring that colleges comply. Since the law was enacted in 1990 though, students, parents and journalists have also audited colleges.

Step 1

Familiarize yourself with campus crime coverage. Our handbook, Covering Campus Crime, discusses crime statistics, security logs and disciplinary records, as well as what to do if officials deny your requests for security and police reports. In addition to the report, we’ve compiled an FAQ answering some of the most common questions regarding the Clery Act.

For more information, be sure to check out:

Step 2

Look through your paper’s archives to see what types of campus crime stories you have reported on in the past. What have campus police or administrators said about safety on campus? Have there been any noteworthy crimes or safety incidents in the past few years? You probably already have a good idea of how safe your campus is, but looking back at what you’ve already reported can help jog your memory of incidents that happened before your time or that you’ve forgotten about. This article by Southern Methodist University’s Daily Campus that looks at the school’s Clery compliance is also worth a read.

Step 3

Find your school in the Department of Education’s online database. Note anything that jumps out at you as surprising or odd. Do the numbers for any of the reporting categories appear low? Do the numbers change drastically from one year to the next? Do you personally know of crimes that don’t appear to have been documented? Your suspicions at this stage in the process will help define the next steps in your reporting process.

Step 4

Next, check and see whether your school has been audited for Clery Act compliance in the past.

If your school hasn’t been audited, move on. If it has, read through the audit reports. Was your school fined? Did the audit turn up anything indicating the school had not fully complied with the requirements? If your school has been cited by the DOE for failing to comply with requirements, it’s important when you follow up to see what, if any, changes the school has made in order to comply with the law.

Step 5

Find your school’s Annual Security Report and Annual Fire Safety Report. These are sometimes, but not always, posted on your school’s website. If you cannot find the report, use the SPLC’s open records request letter generator to generate a request to send to your campus police department. By law, they’re required to provide a paper copy of the report without charge upon request.

Step 6

We’ve written up sample records requests for you to use. Fill out and submit public records requests for information from your campus and local police departments. One of the requests deals with records from your campus police department; another deals with records from your local police department. Modify the template as needed to request any additional records you think will be helpful to your investigation. Contact one of the lawyers at the SPLC if you have questions about your request; our legal hotline number is (703) 807-1904.

Step 7

Print out this Clery Act checklist we’ve compiled, modeled after the scorecard SMU’s Daily Campus compiled. Begin to answer all of the questions on the checklist, either through visiting your local campus police department in person, or by reading through the annual security and fire safety reports. If possible, have two reporters independently complete this step and compare answers. Some of the questions are subjective, so having an extra eye helps to ensure the audit’s accuracy. Don’t hesitate to contact your campus police department for comment or clarification. Ask them to explain why if the school doesn’t appear to be complying with certain Clery Act provisions.

If you’re so inclined, fill out this form to share your results with the SPLC. We’ll review and make the aggregate audit results available for anyone to examine.

Step 8

Brainstorm story ideas and begin reporting. You will likely generate stories from your reporting even before you receive the records from the campus and local police departments. Some suggestions include:

  • Report how your school fared on the checklist. Are there glaring omissions? Did the school do well?
  • Dig into how your campus determines who the Campus Security Authorities are. How does the school collect reports from each person? What kinds of training do these individuals receive? (The DOE’s Clery handbook specifies who must report crimes on pages 74-76).
  • Who is in charge of overseeing the school’s Clery compliance? Is there one individual, or is it a broader effort? What kind of training have they received? How much money does your school spend each year ensuring it complies with the Clery Act requirements?
  • Does the school complete internal audits of its Clery compliance?

Step 9

After you receive the records you’ve requested from campus and local police authorities, begin going through them. Your goal is to see how the police reports compare with the numbers the school reported to the Department of Education and in its Annual Security Report. It’s important to remember that even if the numbers match up completely, it’s still not evidence that your school has complied fully with the Clery rules, since the Clery reports are supposed to include all reports of crimes, even those the campus police may not have investigated themselves (for instance, sexual assaults reported to an RA or team coach).

Step 10

After you’ve analyzed the police records, sit down again and brainstorm story ideas. If the numbers in the police reports wildly contradict the numbers reported in the Annual Security Report, you’ve got yourself a story. If the numbers match up perfectly, you’ve still got a story. And you may find that your school has done well in terms of following the law’s requirements. Ask school officials to justify the numbers. Report on your findings.

More: Download our checklist and sample public records requests