Clery compliance involves the campus community. Obtaining that info at the time of travel or shortly after may take a couple of minutes. Many hands make light work, and public safety receives hundreds of trip forms.
Please submit one online form for each location.
No. WMU Public Safety handles it. (Each law enforcement agency receives a letter from WMU Public Safety explaining the Clery off-campus student trip reporting requirements, a Clery reportable crimes definition sheet that includes categories of hate crime bias, and a spreadsheet with the trip form information and a section for the agency to fill in the crime statistics.)
Yes to all of the above.
Yes. WMU has numerous departments. The only way to determine if a lodging might be a repeated use of a location is if all departments submit student trip forms to public safety.
Below is the scenario that was presented to the Clery Help Desk:
Students from the dance department stay one night at Hotel Y in 2016. The dance department hasn’t stayed there before, so it is not a repeated use of location. In 2017, students from the biology department stay one night at Hotel Y. The biology department also hasn’t stayed there previously.
In 2017 is this considered “repeated use of a location” since now students from two different departments – one dept. in 2016 and another dept. in 2017 - have stayed at Hotel Y? Or is it only if students from the same department stay overnight at the same location every year?
The Clery Help Desk response:
This would be repeated use of Hotel Y by your institution. The individual students, or the department/group the students are affiliated with, does not matter. If your institution makes use of a hotel in consecutive years, it should be counted as noncampus property. We advise you to make a good faith effort to track the hotels that your institution is making use of.
[Note: Public Safety maintains a database of lodging locations.]
The Clery Help Desk response:
If the institution did not make the hotel reservation and does not have any kind of written agreement with a third party to arrange for the hotel reservation, and students have arranged and paid for the hotel themselves, it would not be under the control of the institution. Did the institution have any part in arranging for the space? If not, or if the institution only recommended the space, the institution would not be in control.
[If all the conditions in the Clery Help Desk response above are met, then a trip form is not needed.]
The Clery Help Desk response:
Yes, lodging arranged for and used by a registered student organization and paid for by WMU would be under the control of the institution.
[This means a Clery trip form is required.]
The Clery Help Desk response:
Do you have an agreement for a specific camp site? If so, the area/campsite specified in the agreement would be under the institution’s control. If there are common restrooms or other facilities that are available to your students as part of your written agreement to use the campsite, these areas should also be included.
[This means a Clery trip form is required.]
The Clery Help Desk response:
If your students are using the park without any written agreement, or your written agreement with the park provides your institution with access to the park but no control of a specific space, then no, your institution is not in control of any space. For example, if your students are hiking a trail and set up a tent along the way without arranging for the use of a specific campsite, the area where students camp for the night is not under your institution’s control for Clery Act purposes.
[If all the conditions in the Clery Help Desk response above are met, then a trip form is not needed.]
The Clery Help Desk response:
Yes, through the conference registration the institution has a written agreement with a third party (the conference) to provide housing. The housing arranged for by the third party on your behalf is in the institution’s control.
[This means a Clery trip form is required.]
The Clery Help Desk response:
Regarding reimbursements, presumably there is some pre-existing agreement, approval, or understanding between the institution and the students that the institution will reimburse the students for whatever arrangements the students make (campsite or lodging), either fully or partially, as part of their “travel expenses”. If this is the case, then yes, the institution is in control of the space that the student arranges for.
[This means a Clery trip form is required.]
The Clery Help Desk response:
If a student did not use the travel reimbursement for lodging, then the institution does not have control of the space and the space should not be included in the institution’s noncampus property. The lodging was arranged for and paid for by the student. In these cases, I would advise you to keep internal documentation that the institution’s money was not used to pay for lodging either directly or indirectly (an example of indirectly would be the institution paying a conference registration fee that includes housing arranged for by the conference, this establishes control for Clery Act purposes).
[If all the conditions in the Clery Help Desk response above are met, then a trip form is not needed.]
The Clery Help Desk response:
Although these trips are not part of a post-secondary program, it is still an institutionally sponsored program for students. Presumably, the students are somehow enrolled in this program with your institution. We advise you to count any spaces that your institution controls as part of your noncampus property.
[This means a Clery trip form is required.]
The U.S. Department of Education in the 2016 Edition of The Handbook for Campus Safety and Security Reporting definition is on page 2-2:
Controlled by means that your institution directly or indirectly rents, leases or has some other type of written agreement (including an informal one, such as a letter or an e-mail) for the use of a building or property, or a portion of a building or a property. Even if there is no payment involved in the transaction, for Clery Act purposes, a written agreement for the use of space give your institution control of that space for the time period specified in the agreement.
WMU participates in federal Title IV student financial assistance programs. All postsecondary institutions receiving Title IV funding must comply with the Higher Education Act. The HEA requires disclosure of campus crime statistics and security information. One of the HEA requirements involves providing crime statistics associated with off-campus student trips in the Clery Annual Security Report.
The Clery Help Desk response:
Part of the definition of noncampus includes “for educational purposes”. If the student’s travel is solely for his/her job and not for educational purposes this property does not need to be included in the noncampus category.
The Clery Help Desk response:
Please note that travel by recognized student groups is considered to be part of an institution’s educational purposes.
[This means a form is not required if a student is traveling solely for employment purposes. A form is required if a student is traveling for educational purposes or as part of a recognized student group.]