Campus Security Authority
“Campus Security Authority (CSA)” is a Clery Act-specific term that encompasses four groups of individuals and organizations associated with an institution. An official is defined as any person who has the authority and the duty to take action or respond to particular issues on behalf of the institution.1
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Campus Security Authority (CSA) Defined:
- All individuals who work for UH Hilo's Campus Security Department are campus security authorities.
- Any official of an institution who has significant responsibility for student and campus activities, including, but not limited to, student housing, student discipline and campus judicial proceedings, student athletics, and personnel who are in positions of responsibility over students at off campus and on campus events and activities.
- Any individual or organization to whom or to which the campus community has been directed to report criminal incidents in addition to the security department personnel.
- Any individual who has responsibility for campus security but who does not constitute a campus security department (e.g., an individual who is responsible for monitoring the entrance into institutional property). Include individuals such as those who provide security or monitor access into a campus facility; act as event security, such as for sporting events or large registered parties, or escort students around campus after dark (including other students).
Because official responsibilities and job titles vary significantly on campuses, the law does not state a list of specific job titles. To determine specifically which individuals or organizations are campus security authorities for your institution, consider the function of that individual or office. Look for officials (i.e., not support staff) whose functions involve relationships with students. If someone has significant responsibility for student and campus activities, he or she is a campus security authority. Note that whether or not your institution pays an individual is not a factor in determining whether that individual is a CSA. Be sure to keep your CSA list current so that you do not omit any individual or organization that fits the definition of a CSA.
Examples of individuals (outside of the security department) who generally meet the criteria for being campus security authorities include:
- a dean or director who oversees student housing, a student center, student affairs, student discipline, or student extracurricular activities
- a director of athletics, all athletic coaches (including part-time employees and graduate assistants)
- a faculty advisor to a student group
- a coordinator or director of a student group
- a student resident advisor and assistant
- a student who monitors access to dormitories or buildings that are owned by recognized student organizations
- a Title IX coordinator
- an ombudsperson (including student ombudspersons)
- a director of a campus health center and counseling center
- victim advocates or others who are responsible for assisting with housing relocation, disciplinary action or court cases, etc.
- members of a sexual assault response team (SART) or other sexual assault advocates
- officers from local law enforcement who are contracted by the institution to provide campus safety-related services
- a physician/nurse in a campus health center
- a counselor, including peer counselor (except for professional or pastoral counselors addressed later in this chapter)
- a health educator, including peer health educators
Examples of individuals who would not meet the criteria for being campus security authorities include:
- a faculty member who does not have any responsibility for student and campus activity beyond the classroom
- clerical or cafeteria staff
Institutions are advised to reevaluate the CSA status of all employees (including student employees) on at least an annual basis and document the rationale of the determinations. Please note that, while there may be some overlap, persons considered to be CSAs for Clery Act reporting are not necessarily the same as those defined as “responsible employees” for Title IX.
What Does a Campus Security Authority Do?
The function of a campus security authority is to report those allegations of Clery Act crimes to the official or office designated by the institution to collect crime report information, such as the campus security department or a designated CSA. CSAs are obligated by law to report to the Campus Security Office allegations of Clery Act crimes that are reported to them in their capacity as a CSA. CSAs must report third party allegations only if the reporting party is a reputable source such as an outside counseling agency, doctor, or anyone in a position of similar responsibility.
What Does a Campus Security Authority Not Do?
- CSAs are not responsible for investigating any incident.
- CSAs are not responsible for reporting incidents that they overhear students talking about in a hallway conversation.
- CSAs are not responsible for reporting incidents that a classmate or student mentions during an in-class discussion.
- CSAs are not responsible for reporting incidents that a victim mentions during a speech, workshop, or any other form of group presentation.
- CSAs are not responsible for reporting incidents that the CSA otherwise learns about in an indirect manner.
- A campus security authority is not responsible for determining authoritatively whether a crime took place; that is the function of law enforcement personnel.
- A campus security authority should not try to apprehend the alleged perpetrator of the crime. That, too, is the responsibility of law enforcement.
- It is also not a CSA’s responsibility to try and convince a victim to contact law enforcement if the victim chooses not to do so.
Examples of Collecting Crime Information
- Scenario 1: A resident assistant (RA) who has been identified as a CSA is told by a fellow student that she has been raped and is seeking emotional and medical support. The resident assistant should forward the report to the institution’s designated official for inclusion in the statistics regardless of whether the victim chooses to file a report with law enforcement or press charges. Note: The RA must advise the victim that the crime will be reported and that no information regarding the victim will be diclosed unless the victim provides written approval for the CSA to do so.
- Scenario 2: A student mentions to her boyfriend that a number of rooms on her dorm floor were broken into during the previous night’s football game. Later that day, her boyfriend tells the athletics director (AD) what he heard. The AD asks which dorm it was and what, if anything else, the boyfriend knows about the incident. The AD should document the information and forward it to the school’s campus security department or the institution’s designated official for inclusion in the statistics per the university's crime reporting policy.
- Scenario 3: Ms. Jones, Director of Student Housing, gets a call from the director of a counseling center in town. The caller wants to let the director know that four students from the school sought assistance at the center and told the center’s counselors that they had been sexually assaulted on campus and were seeking emotional support. They did not want police investigations. Even though these are third-party reports, Ms. Jones, believing the report was made in good faith, documents all of the information she was given and forwards the reports to the person or office responsible for collecting Clery Act crime reports at her institution. At UH Hilo, that is the Campus Security Office.
- Scenario 4: Jane, a resident advisor, is attending a "Take Back the Night" rally at her school. She attends the event as a participant and is not involved in providing any counseling services. As part of the event’s programming, a student gives a speech in which she says that she was raped on campus last year. In response to hearing the speech, three other students decide to address the crowd and disclose their own experiences being sexually assaulted. After the event, Jane returns to her room where a student from her housing facility knocks on her door and tells her that she was sexually assaulted at an on-campus party in another housing facility three months ago. Jane should forward the report of the incident that was reported to her as she was acting in her capacity as an RA for her housing facility. Jane should not report the sexual assaults that she heard discussed at the" Take Back the Night" event.
Exemption for Pastoral and Professional Counselors (Note: UH Hilo has no pastoral counselors)
- To be exempt from disclosing reported offenses, the individual must be acting in the role of a professional counselor: one who provides mental health counseling to members of the institution's community. State licensing requirements for professional counselors typically include completion of a minimum of 3,000 hours of post-master’s degree supervised clinical experience, performed within two years before a license is awarded. If an unlicensed counselor has completed master degree course work and is acting in the role of a licensed counselor under the supervision of a licensed professional in order to gain the required supervised clinical experience in a two-year period, he or she would be exempt from CSA requirements. An example is a Ph.D. counselor-trainee acting under the supervision of a professional counselor at the institution.
The pastoral or professional counselor exemption is intended to ensure that these individuals can provide appropriate counseling services without an obligation to report crimes they may learn about. This exemption is intended to protect the counselor-client relationship. However, even the legally recognized privileges acknowledge some exemptions, and there may be situations in which counselors are in fact under a legal obligation to report a crime.
- Scenario 1: A dean of students who has a professional counselor’s license but is employed by the institution only as a dean and not as a counselor, is not exempt from reporting.
- Scenario 2: If that same dean is employed by the institution as both a professional counselor and an academic counselor, and learns of a criminal incident while engaged in academic counseling, that dean is not exempt from reporting the incident.
- Scenario 3: If your institution has an individual with dual roles, one as a professional or pastoral counselor and the other as an official who qualifies as a CSA, and the roles cannot be separated, that individual is considered a CSA and is not exempt from reporting Clery Crimes.
In most cases it is possible for a CSA to fulfill his or her responsibilities while still maintaining victim confidentiality. CSA reports are used by the institution to compile statistics for Clery Act reporting and to help determine if there is a serious or continuing threat to the safety of the campus community that would require an alert (i.e., a timely warning or emergency notification). Those responsibilities can usually be met without disclosing personally identifying information. A CSA report does not need to automatically result in the initiation of a police or disciplinary investigation if the victim does not want to pursue this action.
Excerpt from Campus Safety and Security Handbook, 2016 Edition (Clery Act Handbook), pp. 4.2 - 4.8 ↩︎