Page 22 - Security Today, March 2017

Act crimes brought to their attention to the reporting structure of the college or university. This is important because institutions of higher education are required to collect crime reports from all CSAs at least annually, including from CSAs that may be employed by an affiliated hospital or medical facility.
The Daily Crime Log
An additional matter raised by healthcare settings with their own se- curity departments pertains to the daily crime log. All institutions subject to the Clery Act that have a campus police or security de- partment must create, maintain and make available a daily crime log, which is intended to capture all crimes reported to the department, not just those Clery Act crimes.
The scope of the log is limited to those crimes reported to the security department that occurred On Campus, on Public Property affiliated with the campus, in or on non-campus buildings and prop- erty, or within the security department’s expanded patrol jurisdiction, if one exists. Typically, the institution’s campus police or public safety department is responsible for managing the log for the main campus.
However, if there is a hospital or other affiliated healthcare facil- ity that is part of the main campus, and the facility has its own secu- rity department that is independent of the campus police or public safety department, then the institution should implement a system to ensure that crimes reported to healthcare security are added to the log by the institution’s campus police or public safety department within two business days of the healthcare security department learn- ing about a crime.
Given the presence of a stand-alone security department on the main campus, it is recommended that a copy of the Log be available at the main campus police or public safety department, as well as the
healthcare facility’s security department office. This will ensure the daily crime log is accessible on site, as required by law, regardless of whether the healthcare facility is part of the institution’s main cam- pus or is considered under the Clery Act to be a separate campus.
Toward an Integrated Approach
Healthcare facilities that are affiliated with an institution of higher education or are allowing an institution to use space within their fa- cilities play a valuable role in evaluating a campus’s Clery compliance program in light of the specific compliance considerations presented by these types of arrangements. While some of the more foundation- al issues have been reviewed, it would serve institutions well, given the current compliance environment, to consider a myriad of other ways in which compliance with the Clery Act can be nuanced for its affiliated healthcare facilities, regardless of whether those facilities are owned or operated by the college or university. A proactive, col- laborative review of pertinent policies, procedures and practices per- taining to these facilities can help stave off noncompliance findings in the event of a Department of Education audit.
Dolores A. Stafford is the executive director of the National Association of Clery Compliance Of- ficers and Professionals (NACCOP), president & CEO of D. Stafford & Associates, and a partner of STANLEY Security.
1 https://www.law.cornell.edu/uscode/text/20/1092 http://www.naccop.org/cdn/pdfs/Federal-Register-Final- Rules-Oct-2014.pdf
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