Page 21 - Security Today, March 2017

ing such control for Clery Act purposes. These factors include:
• Whether the facility has overlapping faculty/doctors.
• Whether the facility has overlapping boards of directors or officers.
• Use of the hospital or medical center as part of the institution’s
educational program.
• Geographic proximity.
• An ongoing relationship between the institution and the hospital.
• Whether students consider the hospital or medical center to be
part of the campus.
Institutions will need to consider these factors when determining whether hospitals or other medical centers (or spaces contained therein) are “controlled” by the institution and, therefore, Clery-reportable.
Campus Security Authorities
Regardless of the applicable Clery Geography category into which an affiliated healthcare facility may fit, there are some important consid- erations that institutions owning or controlling these facilities must address. First, the institution will need to identify what the Clery Act calls Campus Security Authorities (CSAs), who are associated with the facility regardless of whether those individuals are employed by the institution or the healthcare facility. Minimally, CSAs include, but are not limited to, the campus police/public safety personnel that provide safety and security services in the healthcare setting, regard- less of whether these individuals are:
• Part of the institution’s campus police or public safety department that provides such services for the rest of the college/university.
• An entity unto themselves (such as a police or security force that
provides security and patrol services exclusively to a hospital af- filiated with an institution), or;
• Are contract security officers that provide supplemental security services to healthcare facilities.
CSAs also include any official of the institution that has signifi-
cant responsibility for student and campus activities, or persons that do not work for the campus police/public safety department but who provide security-related services, such as monitoring access to a col- lege or university owned or controlled facility or parking lot.
Any person meeting the definition of a CSA needs to be notified of this designation and trained in their responsibilities, which primar- ily include documenting and promptly forwarding reports of Clery
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