SUM Clery Act Policy & Purpose
SUM Bible College & Theological Seminary (“SUM” or the “College”) is committed to maintaining a safe and secure environment for its faculty, staff, students, alumni, volunteers, and visitors. The requirements in this policy are designed to facilitate SUM’s compliance with the “Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act of 1998” (the “Clery Act”). The Clery Act requires SUM to disclose specified crime report statistics on and near its campuses, to provide other safety and crime information to the campus community in an accurate, complete, and timely manner, and to maintain written policies and procedures implementing the Clery Act. To maintain a safe and secure environment for its faculty, staff, students, and visitors, and as a recipient of federal financial aid, the College complies with the provisions of the Clery Act.
Scope and Application
This Policy applies broadly to the entire College community, including students who are registered or enrolled in College classes or one of the College’s degree programs (“Students”); all full-time and part-time faculty (“Faculty”); all non-faculty College employees, including College Staff, (“Staff”); and contractors, vendors, visitors, guests, or other individuals who are participating in or seeking to participate in the College’s education program or activities (“Third Parties”).
Definitions
Term | Definition |
---|---|
Campus Security Authority (CSA) | Individuals at SUM who, because of their function, have an obligation under the Clery Act to notify the Office of Clery Act Compliance of potential Clery Crimes that are reported to them, or potential Clery Crimes that they may personally witness. These individuals are designated as Campus Security Authorities based on their position or due to official job duties, ad hoc responsibilities, or volunteer engagements. The obligation to report potential Clery Act crimes observed by them, or reported to them by other individuals, is based on the report itself, without regard to whether the report has been investigated, substantiated, is plausible, or derives from a confidential source of information. CSAs typically fall under one of the following categories: 1. A member of a campus police/security department. 2. Individuals with responsibility for campus security in some capacity (but who are not members of a campus police/security department). 3. Other individuals or offices where a College policy directs students, staff, or faculty to report criminal offenses. 4. Officials with significant responsibility for student and campus activities, including but not limited to, student housing/residential education, student discipline, and campus judicial proceedings. |
Clery Act Crimes (Clery Crimes) | Crimes designated as reportable under the Clery Act include criminal homicide (murder and negligent/non-negligent manslaughter); sex offenses (rape, fondling, statutory rape, and incest); robbery; aggravated assault; burglary; motor vehicle theft; arson; hate crimes (criminal offenses that are motivated by specific types of bias); dating violence; domestic violence; stalking; and arrests or referrals for disciplinary action for any of the following: (a) liquor law violations, (b) drug law violations, and (c) carrying or possessing illegal weapons. |
Clery Reportable Locations (Clery Geography) | Property that is considered by the Clery Act to be (1) on campus, (2) public property within or immediately adjacent to campus, or (3) non-campus buildings or property that the institution owns or controls, is frequented by students, and is used in support of educational purposes; as well as any building or property owned or controlled by a student organization or other institution-associated entity that is officially recognized by the institution Non-campus buildings or property may also include certain College-sponsored overnight trips to locations frequently used by students, controlled by the College (e.g., a lease or rental agreement is in place), and used in support of educational purposes. |
Emergency Notification | A notification that is issued immediately upon confirmation of a significant emergency or dangerous situation occurring on or near campus that poses an immediate threat to the health or safety of members of the campus community. Emergency Notifications can be triggered by a broad range of threats, including but not limited to the following: – Active assailant/armed intruder – Explosion – Bomb threat or suspected explosive device – Civil disturbance/riot – Terrorist incident – Fire – Significant law enforcement activity – Hazardous materials spill – Gas leak – Earthquake – Approaching storm or other extreme weather conditions – Outbreak of serious contagious illness (e.g., coronavirus, meningitis, norovirus) |
Emergency Notification System | A mechanism established for the purpose of and dedicated to enabling SUM officials to quickly contact or send messages to faculty, staff, and students in the event of an emergency. Examples include but are not limited to, fire alarms, sirens, alerts via email/text message, local TV/Radio, etc. |
Timely Warning | An alert that is issued to the campus community about a Clery Act Crime, occurring within a Clery Reportable Location, which represents a serious or continuing threat (e.g., a murder, sex offense or robbery). |
Policy Details
In accordance with the requirements of the Clery Act, the College shall:
Publish an Annual Security and Fire Safety Report (ASFSR)
By October 1st each year (or as otherwise required by the U.S. Department of Education), SUM will publish an ASFSR documenting the prior three calendar years of Clery Act crime statistics, security policies and procedures, and information on the basic rights guaranteed to victims of sexual assault, dating violence, domestic violence and stalking. All crime statistics must also be submitted to the U.S. Department of Education’s online portal.
This report must be made available to all current faculty, staff, and students. In addition, prospective faculty, staff, and students must be notified of the ASFSR’s existence and provided a copy upon request. Paper copies of the report will be available upon request from the SUM Department of Public Safety (DPS). In addition, the Office of Admissions and Human Resources will publish a link to the ASFSR with a brief description on their respective websites.
Identify, Notify, & Train Campus Security Authorities (CSAs)
SUM will identify positions which meet the definition of a CSA on an ongoing basis and notify individuals in these roles of their obligations under the Clery Act to report any and all alleged Clery Crimes that they witness, or are reported to them, which may have occurred in a Clery Reportable Location. SUM requires that all CSAs complete annual training on their responsibilities and reporting requirements under the Clery Act. SUM will provide such training on a regular basis through the SUM student portal learning management system.
Disclose Crime Report Statistics
Crime report statistics for incidents that occur in Clery Reportable Locations and are reported to Campus Security Authorities must be disclosed in a variety of formats, including the daily crime log, the ASFSR, and through the U.S. Department of Education’s online portal.
The Clery Act Compliance Coordinator is responsible for gathering crime report statistics from DPS; Office of Professionalism and Ethics (OPE); Office of Equity, Equal Opportunity and Title IX (EEO-TIX); Student Judicial Affairs and Community Standards (SJACS); Residential Education; Human Resources; Athletics; all Campus Security Authorities (CSAs); and from local, state, national and international law enforcement agencies.
Disclosures of Clery Crimes occurring on Clery Geography made to a professional counselor or pastoral counselor in the context of a privileged (confidential) communication, are not subject to reporting requirements under this Policy. If information provided in confidential disclosures is believed to represent a serious or continuing threat to the safety of the campus community by the recipient of that confidential information, then that information may be shared with a CSA and, as a result of the CSA receiving the information, the information must be evaluated for Clery purposes.
The Clery Act requires reporting of crimes in the following categories:
- Criminal Offenses:
- Criminal Homicide
- Murder & Non-negligent manslaughter
- Negligent manslaughter
- Sex Offenses
- Rape
- Fondling
- Statutory Rape
- Incest
- Robbery
- Aggravated Assault
- Burglary
- Motor Vehicle Theft
- Arson
- Criminal Homicide
- VAWA Offenses:
- Domestic Violence
- Dating Violence
- Stalking
- In addition, SUM must gather statistics for the following categories of arrests or referrals for disciplinary action if an arrest was not made:
- Liquor Law Violations
- Drug Law Violations
- Carrying or Possessing Illegal Weapons
- SUM must also report the following Hate Crimes by category of prejudice, including race, gender, religion, sexual orientation, ethnicity, national origin, gender identity and disability. Statistics are required for the offenses listed above in addition to the four additional categories listed below, if the crime committed is classified as a Hate Crime:
- Larceny/Theft
- Simple Assault
- Intimidation
- Destruction/Damage/Vandalism of Property
- SUM must also disclose if it has determined that any of the previously listed crimes are “Unfounded.” The Clery Act has specific guidelines for classifying a reported offense as “Unfounded,” which can only occur through the action of sworn law enforcement agencies.
Issue Timely Warnings
SUM must provide timely warnings in response to reports about Clery Crimes, occurring within a Clery Reportable Location, which represent a serious or continuing threat to members of the campus community. This is determined on a case-by-case basis by one (or more) SUM official(s) who has been pre-identified in SUM’s Policy and Procedures for Issuing a Timely Warning. A report does not need to include personally identifiable information in order to initiate the Timely Warning determination process. Because the nature of criminal threats is often not limited to a single location, timely warnings must be issued in a manner likely to reach the entire campus community. Timely warnings will not include the name of the victim [Refer to Policy and Procedures for Issuance of College Alerts.]
As noted above, if information provided in confidential disclosures is believed to represent a serious or continuing threat to the safety of the campus community by the recipient of that confidential information, then that information may be shared with a CSA and, as a result of the CSA receiving the information, the information must be evaluated for Clery purposes.
Issue Emergency Notifications
SUM is required to inform the campus community about a significant emergency or dangerous situation involving an immediate threat to the health or safety of SUM faculty, staff, employees, students, and visitors occurring on campus. Emergency events may be localized; therefore, notifications may be tailored exclusively to the segment of the campus community at risk.
SUM also must have emergency response and evacuation procedures in place specific to its on-campus facilities. A summary of these procedures must be disclosed in the ASFSR. Additionally, the emergency response procedures must be tested at least once, annually. [Refer to Policy and Procedures for Issuance of College Alerts.]
Exception: Emergencies where issuing a notification would compromise efforts to assist a victim, contain the emergency, respond to the emergency, or mitigate the emergency are not subject to the emergency notification requirement.
Respond to Reports of Missing Residential Students
SUM provides every student living in on-campus housing the opportunity and means to identify an individual to be contacted in an emergency, including whenever officials determine that a student is missing.
SUM shall investigate all reports of missing students and will notify and cooperate with other law enforcement agencies, as necessary, to further the investigation.
Compile, Report and Publish Fire Data
The Office of Fire Safety and Emergency Planning will produce the information to be included in the ASFSR, which is part of the combined ASFSR. The Office of Fire Safety and Emergency Planning must collect and disclose fire statistics for each on-campus student housing facility separately for the three most recent calendar years for which data are available in accordance with Higher Education Opportunity Act of 1998 (HEOA) regulations. Each such facility must be identified in the statistics by name and street address, regardless of whether any fires have occurred.
Additionally, the Office of Fire Safety and Emergency Planning will provide a description of the fire safety systems in each student housing facility that is included in the ASFSR. These descriptions should include mechanisms (e.g., fire extinguishers, fire doors, posted evacuation routes, etc.) or systems related to the detection, warning and control of a fire. The Office of Fire Safety and Emergency Planning will submit the ASFSR to the Clery Act Compliance Coordinator for inclusion in the statistics reported to the U.S. Department of Education. [Refer to ASFSR.]
Maintain a Public Daily Crime Log
SUM must maintain a daily crime log documenting the “nature, date, time and general location of each crime” reported to DPS within the last 60 days, and the disposition, if known, of the reported crimes. Incidents must be entered into the log within two business days of receiving the report. The Daily Crime Log does not include personally-identifiable information about the victim or the accused. The Daily Crime Log is available within DPS, during normal business hours, and on the DPS website [Daily Crime Log]. Requests for public inspection of daily crime log entries beyond 60 days must be made in writing to the Records Manager within DPS and will be made available to the requestor within two business days of the request.
Ensure Victim Rights, Options, and Resources
Victims of sexual assault, domestic violence, dating violence, and stalking have specific rights, options, and resources required by the Clery Act. Individuals accused of sexual assault, domestic violence, dating violence, and stalking also have specific rights required by the Clery Act.
SUM must provide victims of sexual assault, domestic violence, dating violence, and stalking a written explanation of their rights. These rights include supportive measures, like the option for a relocation/change of housing, transportation, or academic course assignment. They also include access to counseling services, legal services, and assistance with making a report to law enforcement.
All disciplinary proceedings must be conducted by individuals who are trained annually on the issues related to domestic violence, dating violence, sexual assault and stalking and how to conduct an investigation and hearing process that protects the safety of victims and promotes accountability. Disciplinary proceedings are required to be prompt, fair, and impartial, and must confer certain procedural rights to both the accuser and the accused, including the right to an advisor of choice, equal and timely access to information that will be used in any disciplinary meeting or proceeding, and simultaneous written notification of the finding and sanction (and the rationale for each). These rights are incorporated into the Policy on Prohibited Discrimination, Harassment, and Retaliation, and accompanying Resolution Processes.
Prevention and Awareness Programs
SUM is required to develop education, primary prevention and awareness programs for all incoming students and new employees, and ongoing prevention and awareness campaigns for students and faculty.These programs must include definitions of prohibited conduct, safe and positive options for bystander intervention, information on risk reduction to recognize the warning signs of abuse behavior and how to avoid potential attacks, possible sanctions and protective measures, procedures for reporting to campus or external law enforcement authorities, and procedures for disciplinary action.
Maintain a Public Daily Fire Log
SUM maintains a daily fire log in conjunction with the daily crime log documenting the nature of the fire, date the fire occurred, date and time the fire was reported and general location of each fire-related incident in an on-campus student housing facility reported to any SUM official. Incidents must be entered into the log within two business days of receiving the report and the previous 60 days of fire log entries must be available for public inspection during normal business hours. Requests for public inspection of daily fire log entries beyond 60 days must be made in writing to the Records Manager within DPS and will be made available to the requestor within two business days of the request.
Procedures
Notifications
SUM sends an annual Clery notification to all students, staff, faculty and administrators containing updated information on policies and procedures in addition to the annual safety report. Additionally, students, staff, faculty and administrators are notified of emergency health and safety alerts including fires and crimes committed on and around campus and student housing, received through local law enforcement agencies. These notifications are sent by the Department of Student Life and Ministry through the regular student communication platforms including email, text, website notification and canvas notifications.
Crime and Fire Log
A daily Crime and Fire Log is maintained by the office of Student Life and Ministry. Each entry indicates the date, time, nature of the offense and location of the offense. Crime and Fire information is gathered from student incident reports, staff, faculty, residence directors and assistants, and student life staff. Additional emergency alerts are received through local law enforcement agencies.
Prior to completing the annual report, the office of Student Life and Ministry contacts the El Dorado Hills Sherrifs office to receive a comprehensive summary of all incidents reported on and around campus and student housing. These reports are compared with SUM’s daily crime and fire log and documents updated accordingly. All documentation is then stored on the shared google drive file regarding student safety and notification.
Training
Personal safety and reporting training is provided for students by the Student Life and Ministry Department in annual student orientation sessions and to faculty, staff and administration through the HR department.
Responsibilities
Clery Act Compliance | – Monitor SUM’s compliance with the Clery Act; – Update the requirements in this policy as necessary; – Annually review geographic categories for inclusion in the College’s Clery Geography; – Establish a procedure for processing instances of short-stay away trips in order to designate a CSA to disclose any Clery Crimes reported during the trip to be potentially included in the ASFSR; – Identify those positions with CSA responsibilities and notifying those individuals; – Maintain a list of CSAs; – Develop procedures for reporting crime statistics by CSAs; – Educate and train CSAs, and personnel within DPS and other key stakeholders as necessary; – Annually, request in writing crime statistics from local law enforcement with jurisdiction over SUM’s Clery geography; – Prepare the ASFSR and disclosing statistics of Clery Crimes reported over the past three years; – Provide assistance as needed in cooperation with other departments that maintain and publish SUM policies and procedures addressing campus security and safety; – Submit the crime and fire statistics to the U.S. Department of Education; – Oversee the regular reconciliation of campus crime data amongst offices that house significant numbers of campus crime reports, including EEO-TIX, OPE, SJACS Residential Education, DPS and Human Resources. |
Public Safety (PS) | – Report crime statistics (as specified in the Clery Act); – Issue Timely Warning alerts to the campus community about Clery Crimes; – Coordinate Emergency Notifications to the campus community when deemed necessary and appropriate; – Compile and provide to the Clery Act Compliance Coordinator, statistics of reports of Clery Crimes reported to DPS; – Monitor criminal activity at off-campus locations of student organizations officially recognized by SUM; – Investigate all reports of missing students by notifying and cooperating with other law enforcement agencies, as required; – Provide paper copies of the ASFSR upon request; – Annually, provide information related to any education or awareness programming conducted for inclusion in the ASFSR; – Maintain the daily crime and fire logs; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
SUM Residential Housing | – Immediately report any alleged Clery Crime to the Office of Clery Act Compliance for a Timely Warning consideration; – Provide a list of all on-campus residential facilities annually for review and potential inclusion in the ASFSR; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Campus Director | – Immediately report any alleged Clery Crime to the Office of Clery Act Compliance for a Timely Warning consideration; – Provide all conduct referral data to the Clery Act Compliance Coordinator for review and potential inclusion in the ASFSR; – Annually, provide information related to any education or awareness programming conducted for review and potential inclusion in the ASFSR; – In partnership with other College departments, ensure the availability of Clery Act defined awareness and prevention programming for all students. Such programming will be part of SUM’s awareness and prevention campaign. This programming will be identified, provided or facilitated in collaboration with campus and local subject matter experts, with guidance from the campus sexual assault climate survey, other evidence-based research, and outcomes assessments satisfying the Clery Act requirements and definitions; – Provide the Clery Act Compliance Coordinator with a list of advisors to campus recognized groups, clubs, and organizations; and ensure each of these advisors has completed Campus Security Authority training; and – Ensure all disciplinary proceedings are conducted by trained parties and proceedings are prompt, fair, and impartial, and must confer certain procedural rights to both the accuser and the accused; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Fire Safety and Emergency Management | – Conduct an annual emergency alert exercise and test the emergency alert system in conjunction with the exercise; – Collect fire statistics relative to each on-campus student housing facility; – Produce the ASFSR in accordance with the current legislation and updating the ASFSR language to reflect legislative updates and interpretations; – Provide and maintain ASFSR statistics to the Office of Clery Act Compliance; Maintain the daily fire log; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Admissions (Undergraduate and Graduate) | – Notify and provide the online location of the ASFSR and a brief description of the report to prospective or current students; and – Provide a paper copy of the ASFSR upon request to a prospective or current student. |
Academic and Faculty Affairs | – Provide curricular and co-curricular travel documentation to the Clery Act Compliance Coordinator for assessment of Clery Act non-campus property reporting obligations; and – Provide the Clery Act Compliance Coordinator with all academic locations each semester for determination of the applicability of the Clery Act at those locations; and – Provide all conduct referral data to the Clery Act Compliance Coordinator for review and potential inclusion in the ASFSR. |
Resources | – Notify and provide to prospective faculty and staff the online location of the ASFSR and a brief description of the report; – Provide a paper copy of the ASFSR upon request to a prospective or current faculty or staff member; – Immediately report any alleged Clery Crime to the Office of Clery Act Compliance for a Timely Warning consideration; – Annually, provide all conduct referral data to the Clery Act Compliance Coordinator for review and potential inclusion in the ASFSR; – Annually, provide information related to any education or awareness programming conducted for review and potential inclusion in the ASFSR; – In partnership with other College departments, ensure the availability of Clery Act defined awareness and prevention programming for all students. Such programming will be part of SUM’s awareness and prevention campaign. This programming will be identified, provided or facilitated in collaboration with campus and local subject matter experts, with guidance from the campus sexual assault climate survey, other evidence-based research, and outcomes assessments satisfying the Clery Act requirements and definitions; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Diretor of Student Life and Ministry | – Immediately report any alleged Clery Crime to the Office of Clery Act Compliance for a Timely Warning consideration; – Annually, provide aggregate Clery Act reportable data to the Clery Act Compliance Coordinator for review and potential inclusion in the ASFSR; – Annually, provide information related to any education or awareness programming conducted for inclusion in the ASFSR; – In partnership with other College departments, ensure the availability of Clery Act defined awareness and prevention programming for all students. Such programming will be part of SUM’s awareness and prevention campaign. This programming will be identified, provided or facilitated in collaboration with campus and local subject matter experts, with guidance from the campus sexual assault climate survey, other evidence-based research, and outcomes assessments satisfying the Clery Act requirements and definitions; – Provide individuals who report sexual assault, domestic violence, dating violence, and stalking with a written explanation of their rights, including the option for a relocation/change of housing, transportation, or academic course assignment and access to counseling services, legal services, and law enforcement notification; – Ensure all disciplinary proceedings are conducted by trained parties and proceedings are prompt, fair, and impartial, and must confer certain procedural rights to both the accuser and the accused; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Residential Director | – Immediately report any alleged Clery Crime to the Office of Clery Act Compliance for a Timely Warning consideration; – Annually, provide aggregate Clery Act reportable data to the Clery Act Compliance Coordinator for review and potential inclusion in the ASFSR; and – Provide an appropriate representative to serve on the Clery Act Interdisciplinary Review Team to ensure that the office has the opportunity to provide comprehensive oversight, review, revision, and implementation of all College policies and procedures as required by the Clery Act. |
Campus Security Authorities | – Understand the requirements of the Clery Act pertaining to Clery Crimes; – Undergo training and education as determined by the Clery Act Compliance Coordinator; and – Immediately report alleged Clery Crimes to the Office of Clery Act Compliance. |
Most-Recent Clery Act | The most-recent Clery Act Campus Safety, Fire, and Security Survey may be found via the following links: College Navigator – SUM Bible College and Theological Seminary (ed.gov) |
Contacts
Please direct any questions regarding this policy to:
OFFICE | PHONE | |
Office of Clery Act Compliance | 916-306-0874 | [email protected] |
Annual Review and Periodic Updates
This Policy reflects the College’s good faith effort to implement the Clery Act, and to conform the obligations imposed under the Clery Act with other federal laws, including Title IX, as well as state law applicable to students and employees. The College reserves the right to modify this Policy as necessary to comply with federal or state law, and such modifications may be made at any time. Given the evolving nature of the legal requirements related to the Clery Act, and the desire to provide accessible, effective, and legally-complaint policies and procedures, the Office of Clery Act Compliance will review this policy on at least an annual basis.
A student is defined as one whose enrollment has begun (typically, enrollment begins on the first scheduled day of classes of a student’s program), and who (a) is currently participating in one of the College’s degree or non-degree programs; (b) has completed the immediately preceding semester and/or has registered for the next scheduled semester; (c) is officially representing the College during a period between regular academic semesters; and/or (d) is not officially registered for a particular semester but who has a continuing relationship with the College
These forms of prohibited conduct are also governed by the College’s Policy on Prohibited Discrimination, Harassment, and Retaliation, and related Resolution Processes.
CLERY ACT COMPLIANCE
The Jeanne Clery Act (1990, 1998) requires higher education institutions to report crime statistics to current and prospective students and employees. For more information concerning the Jeanne Clery Act please see page 56 of the Student Handbook.
- 2021-22 Campus Safety and Security Report
- 2020-21 Campus Safety and Security Report
- 2019-20 Campus Safety and Security Report
- 2018-19 Campus Safety and Security Report
- 2017-18 Campus Safety and Security Report
- 2016-17 Campus Safety and Security Report
- 2015-16 Campus Safety and Security Report
- 2014-15 Campus Safety and Security Report
- 2013-14 Campus Safety and Security Report
Principles, Purposes, and Goals
The following principles, purposes, and goals, were duly drafted through a committee with various representatives from within SUM Bible College and Theological Seminary. It was approved with amendments by the Executive Committee in the summer of 2014.
The Mission of SUM Bible College and Theological Seminary is guided by the following Foundational Principles, institutional goals and objectives which form the basis of SUM’s educational programs.